(dissenting).
I respectfully dissent. Because MCL 700.3407(l)(a) places the burden on the petitioner to prove heirship, and appellee Ernest Lee Umble is attempting to establish heirship, he has the burden to prove his status as an heir. Accordingly, I would place the burden to establish heirship on Umble, and I believe the proper analysis of this case is as follows:
In 1931, Carl Cedrick Umble, the paternal grandfather of decedent, Kenneth James Koehler, died in a knife fight that began after Clyde Shadwick approached Carl Umble as he and Florence Koehler, who was then pregnant with Carl Umble’s child, were kissing. At that time, Carl Umble was married to Lyndall Hackett, with whom he had a legitimate child. He could not have known that his decisions would seriously complicate the administration of his grandson’s estate.
Appellant, Sherry Bierkle, appeals by delayed leave granted the probate court’s order granting summary disposition in favor of appellee, Ernest Lee Umble. Bierkle raises two issues on appeal. First, the probate court ruled that Umble is a paternal heir to Kenneth Koehler under the Estates and Protected Individuals Code (EPIC), MCL 700.1101 et seq. Bierkle contends that the trial court erred. I disagree and conclude that the trial court correctly found that Umble is a paternal relative under EPIC.
Second, Bierkle contends that the trial court incorrectly decided that MCL 700.2114(4), which precludes a natural parent from inheriting from a child whom the parent failed to acknowledge or refused to support, cannot apply to a case in which a parent predeceased the child. I agree and conclude that MCL 700.2114(4) can apply, and I further conclude that unresolved *688factual issues exist regarding whether Carl Umble acknowledged or refused to support Carl Koehler. I would reverse and remand for further proceedings consistent with this opinion.
I. FACTUAL BACKGROUND
In February 2012, Kenneth Koehler died intestate with a distributable estate of about $500,000. Kenneth Koehler had no children or siblings, and his parents predeceased him. On July 8, 2013, Sherry Bierkle, Kenneth Koehler’s maternal cousin, filed a final accounting and a proposed settlement of Kenneth Koe-hler’s estate among his maternal relatives. On July 23, 2013, Ernest Umble objected to Bierkle’s proposed settlement. Ernest Umble asserted that he was Kenneth Koehler’s paternal uncle. The family tree is as follows:
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A news article from February 8, 1931, provides the context for Carl Umble’s death. Carl Umble had been “separated for several months from his wife, Mrs. Lydia Hackett Umble . . . .” Florence Koehler and Carl Umble quarreled and he “failed to revive the girl’s affection for him,” but he was “reported to have threatened violence to anyone who went out with [Koe-hler] . . . .” Clyde Shadwick, who admitted to stabbing *689Carl Umble, stated that he was “knocked down by a blow of Umble’s fist” after he approached Umble and Florence Koehler as Umble “started to kiss her . . . Carl Koehler was born about three months later, and his Colorado birth certificate listed Carl Umble as his father.
Bierkle filed a proposed settlement of Kenneth Koe-hler’s estate among his maternal relatives. Shortly afterward, Ernest Umble filed objections, asserting that Kenneth Koehler’s paternal relatives1 were entitled to half of the estate. Bierkle filed for summary disposition, asserting that even if Carl Umble was Carl Koehler’s natural father, Ernest Umble could not be an heir to Kenneth Koehler’s estate at law. According to Bierkle, Carl Umble was barred from inheriting as a matter of law because MCL 700.2114(4) provides that a parent may not inherit through a child whom the parent did not acknowledge or failed to support. According to Bierkle, it is impossible for a predeceased parent to establish that he or she acknowledged or supported an afterborn child.
Ernest Umble responded that the probate court should grant summary disposition in his favor under MCR 2.116(I)(2) because MCL 700.2114(4) does not apply if the parent predeceased the birth of the child. According to Ernest Umble, this subsection conflicts with other provisions of EPIC. Following a hearing, the probate court granted summary disposition in favor of Ernest Umble. It reasoned that applying MCL 700.2114(4) to cases in which a child predeceased the parent would conflict with other sections of EPIC.
The probate court held a bench trial to determine whether Carl Umble was the natural father of Carl *690Koehler. Following proofs by both parties, the probate court found that Carl Umble was Carl Koehler’s father and was entitled to inherit through him. As a result, it sustained Ernest Umble’s objections to the proposed settlement of Kenneth Koehler’s estate and ruled that Kenneth Koehler’s paternal relatives should inherit half of the estate.
Bierkle now appeals. The questions this Court must answer to resolve the issues presented are (1) whether Carl Umble was the father of Carl Koehler for the purposes of EPIC, and (2) whether MCL 700.2114(4) applies to cases involving afterborn children.
II. STANDARDS OF REVIEW
This Court reviews for clear error the probate court’s factual findings. In re Bennett Estate, 255 Mich App 545, 549; 662 NW2d 772 (2003). Its findings are clearly erroneous if this Court is definitely and firmly convinced that the probate court made a mistake. Id.
We review de novo issues of statutory interpretation. In re Casey Estate, 306 Mich App 252, 256; 856 NW2d 556 (2014). If the plain and ordinary meaning of a statute’s language is clear, we will enforce the statute as written. Id. We must consider the statute as a whole and in context, giving every word meaning and avoiding constructions that render parts of the statute surplusage. Id. at 257. We should not write into a statute provisions that the Legislature did not include. Id.
We review de novo the probate court’s decision on a motion for summary disposition. Id. at 256. “A motion under MCR 2.116(C)(8) tests the legal sufficiency of the claim as pleaded . . . .” Id. The probate court properly grants summary disposition if the moving party is entitled to judgment as a matter of law. *691MCR 2.116(C)(8). The probate court may grant summary disposition to the nonmoving party under MCR 2.116(I)(2) if “the opposing party, rather than the moving party, is entitled to judgment. . . .”
III. BACKGROUND LAW
Bierkle asserts that the probate court clearly erred when it found that Carl Umble was the natural father of Carl Koehler. Whether Carl Umble was Carl Koehler’s father for purposes of EPIC is important in this case because it determines whether Ernest Umble can inherit as a paternal descendant. If Carl Umble was entitled to inherit from his child, Carl Koehler, Ernest Umble is the only surviving descendant of Kenneth Koehler’s paternal grandparents, and he is entitled to inherit half of Kenneth Koehler’s estate. Otherwise, Bierkle and the other descendants of Kenneth Koehler’s maternal grandparents will inherit the entire estate.
Article II, part 1 of EPIC governs the rights to an intestate inheritance. In re Certified Question, 493 Mich 70, 76-77; 825 NW2d 566 (2012). Some basic definitions are necessary to understand the order of inheritance. EPIC defines “descendant” as “in relation to an individual, all of his or her descendants of all generations, with the relationship of parent and child at each generation being determined by the definitions of child and parent contained in this act.” MCL 700.1103(k). EPIC defines a “parent” as “an individual entitled to take, or who would be entitled to take, as a parent under this act by intestate succession from a child who dies without a will and whose relationship is in question.” MCL 700.1106(i).
If a decedent dies intestate and has no surviving spouse, EPIC provides the order in which the decedent’s estate will pass to his or her surviving relatives. *692MCL 700.2103. First, the estate will pass to the decedent’s descendants. MCL 700.2103(a). If the decedent has no descendants, the estate will pass to the decedent’s surviving parent or parents. MCL 700.2103(b). If the decedent has neither descendants nor surviving parents, the estate will pass to the descendants of the decedent’s parents (the decedent’s siblings, nieces, and nephews). MCL 700.2103(c).
If the decedent has no surviving descendants, parents, or descendants of parents, EPIC instructs the probate court to determine whether there are any descendants of the decedent’s grandparents. MCL 700.2103(d). Half of the decedent’s estate passes to the decedent’s paternal grandparents or their descendants, and half of the decedent’s estate passes to the decedent’s maternal grandparents or their descendants. MCL 700.2103(d). Finally, “[i]f there is no surviving grandparent or descendant of a grandparent on either the paternal or the maternal side, the entire estate passes to the decedent’s relatives on the other side in the same manner as the V2.” Id. The burden of establishing heirship is on the petitioner. MCL 700.3407(l)(a).2
Accordingly, if Carl Umble was entitled to inherit as Carl Koehler’s parent, Ernest Umble is entitled to inherit half of Kenneth Koehler’s estate because he is the sole surviving descendant of Kenneth Koehler’s paternal grandparents. But if inheritance could not pass up to Carl Umble through his relationship with Carl Koehler, it cannot pass back down to Ernest Umble, and he is not entitled to a portion of the estate.
*693IV. ERNEST UMBLE’S RELATIONSHIP TO KENNETH KOEHLER
EPIC provides that, generally, a child is the child of his or her natural parents even if they were not married at the time of the child’s birth:
Except as provided in subsections (2), (3), and (4), for purposes of intestate succession by, through, or from an individual, an individual is the child of his or her natural parents, regardless of their marital status. [MCL 700.2114(1).]
MCL 700.2114(l)(b) sets forth circumstances in which a man is considered to be the natural parent of a child when that child is conceived out of wedlock. In this case, the probate court proceeded under MCL 700.2114(l)(b)(ü). This subparagraph provides that:
[r]egardless of the child’s age or whether or not the alleged father has died, the court with jurisdiction over probate proceedings relating to the decedent’s estate determines that the man is the child’s father, using the standards and procedures established under the paternity act,. .. MCL 722.711 to 722.730.
Michigan’s Paternity Act “was created as a procedural vehicle for determining the paternity of children born out of wedlock. . . In re MKK, 286 Mich App 546, 557; 781 NW2d 132 (2009) (quotation marks and citations omitted). The Paternity Act provides four ways by which a court may establish paternity and issue an order of filiation:
(a) The finding of the court or the verdict determines that the man is the father.
(b) The defendant acknowledges paternity either orally to the court or by filing with the court a written acknowledgment of paternity.
(c) The defendant is served with summons and a default judgment is entered against him or her.
*694(d) Genetic testing . . . determines that the man is the father. [MCL 722.717(1).]
The party seeking to prove paternity must establish by a preponderance of the evidence that the man is the child’s father. Bowerman v MacDonald, 431 Mich 1, 14; 427 NW2d 477 (1988).
This case did not involve a written acknowledgment of paternity, a default judgment, or genetic testing. Instead, the probate court relied on the documentary evidence that the parties presented at the bench trial. Bierkle specifically challenges the probate court’s reliance on Carl Koehler’s birth certificate, which listed Carl Umble as his father.
I agree with Bierkle that this birth certificate does not definitively establish that Carl Umble was Carl Koehler’s father. But the statement on which Bierkle relies from the probate court’s opinion is taken out of context. A full review of the probate court’s opinion reveals that the probate court did not solely rely on the birth certificate. It was only part of the evidence the court considered.
In its findings, the probate court specifically noted that Carl Umble was killed in a knife fight over the affections of Florence Koehler, Carl Koehler’s mother; a newspaper article and death certificate indicated that Carl Umble’s mother was Grace Umble, and Carl Koehler’s obituary listed his grandmother as Grace Roberts of Denver, Colorado; and Carl Koehler’s marriage certificate listed his father as “Carl Sedric [sic] Umble.” Given the body of evidence and the lack of evidence that Carl Koehler’s father was someone else, I am not definitely and firmly convinced that the probate court made a mistake when it found that a preponderance of the evidence supported its finding that Carl Umble was Carl Koehler’s father.
*695V. ACKNOWLEDGMENT AND SUPPORT
That Carl Umble was Carl Koehler’s natural father does not automatically mean that he is entitled to inherit through Carl Koehler. Bierkle contends that the probate court erred when it determined that MCL 700.2114(4) cannot apply in circumstances where the parent dies before the child is born. Bierkle also contends that MCL 700.2114(4) bars Ernest Umble from inheriting as a matter of law because it is impossible for a natural parent to acknowledge or support an afterborn child. I agree in part. I conclude that the probate court erred when it concluded that MCL 700.2114(4) can only apply in cases involving living parents, but I conclude that it does not bar Ernest Umble from inheriting as a matter of law.
A. STATUTORY LANGUAGE
The probate court denied Bierkle’s motion for summary disposition because it accepted Ernest Umble’s argument that the exception in MCL 700.2114(4) could not apply in this case.
As previously noted, EPIC also provides “[e\xcept as provided in subsections (2), (3), and (4), for purposes of intestate succession by, through, or from an individual, an individual is the child of his or her natural parents, regardless of their marital status.” MCL 700.2114(1) (emphasis added). Subsection 4 provides:
Inheritance from or through a child by either natural parent or his or her kindred is precluded unless that natural parent has openly treated the child as his or hers, and has not refused to support the child. [MCL 700.2114(4).]
To accept Ernest Umble’s argument that MCL 700.2114(4) cannot apply in this case is to essentially *696write an additional condition into MCL 700.2114(4), a clause that would read “unless the child is an afterborn child.” This Court does not read clauses into unambiguous statutory language. Casey Estate, 306 Mich App at 257. However, the probate court accepted Ernest Umble’s argument, concluding that MCL 700.2114(4) did not apply in such cases because it would be impossible for the predeceased parent to comply and other statutory sections allow for inheritance through predeceased parents. I conclude that the probate court erred when it decided that MCL 700.2114(4) does not apply to cases involving afterborn children.
If the language of the statute is unambiguous, we must enforce the statute as written. Casey Estate, 306 Mich App at 257. We should not read language into an unambiguous statute. McCormick v Carrier, 487 Mich 180, 209; 795 NW2d 517 (2010). A statute “is ambiguous only if it irreconcilably conflicts with another provision, ... or when it is equally susceptible to more than a single meaning.” Mayor of Lansing v Pub Serv Comm, 470 Mich 154, 166; 680 NW2d 840 (2004) (quotation marks and citation omitted).
The probate court implicitly found that MCL 700.2114(4) is ambiguous when it reasoned that applying this subsection to cases involving afterborn children would conflict with other sections of EPIC. Specifically, the probate court cited MCL 700.2114(3), MCL 700.2104, MCL 700.2107, and MCL 700.2108 as conflicting provisions. I will analyze each of these statutory provisions in turn.
MCL 700.2114(3) provides that termination of parental rights precludes a parent from inheriting:
The permanent termination of parental rights of a minor child by an order of a court of competent jurisdic*697tion; ... or by any other process recognized by the law governing the parent-child status at the time of termination, excepting termination by emancipation or death, ends kinship between the parent whose rights are so terminated and the child for purposes of intestate succession by that parent from or through that child.
By its plain language, MCL 700.2114(3) applies to actions terminating parental rights. While MCL 700.2114(3) recognizes that death does not terminate a parental relationship, this has no bearing on the operation of MCL 700.2114(4). MCL 700.2114(4) does not terminate the parental relationship by death; it precludes inheritance if the parent did not acknowledge or refused to support the child. Not only does this case not involve termination of parental rights or any law governing parent-child status at the time of termination, but even in a case that did, I am unable to determine any ways in which these sections irreconcilably conflict. I conclude that MCL 700.2114(3) does not conflict with MCL 700.2114(4).
MCL 700.2104 provides that “[a]n individual who fails to survive the decedent by 120 hours is considered to have predeceased the decedent for purposes of. . . intestate succession . . . .” This section concerns the death of the child, not the parent, and it does not touch on the parent-child relationship at all. This section would not irreconcilably conflict with MCL 700.2114(4) even if both the decedent and unborn child died within 120 hours of each other. I conclude that MCL 700.2104 and MCL 700.2114(4) do not conflict.
MCL 700.2107 provides that “[a] relative of the half blood inherits the same share he or she would inherit if he or she were of the whole blood.” Nothing in MCL 700.2114(4) contradicts this section. MCL 700.2114(4) is only concerned with whether a natural father has acknowledged and has not refused to support a child. *698That child’s blood relationship to other children is not at issue. MCL 700.2107 and MCL 700.2114(4) do not conflict.
MCL 700.2108 provides that “[a]n individual in gestation at a particular time is treated as living at that time if the individual lives 120 hours or more after birth.” Rather than conflicting, this actually supports the application of MCL 700.2114(4) in cases in which the natural parent predeceases the child. It instructs the probate court to treat an afterborn child as though the child was a living child at the time of the parent’s death. This section does not conflict with MCL 700.2114(4), which does not, by its language, exclude afterborn children from consideration. I conclude that MCL 700.2108 and MCL 700.2114(4) do not conflict.
I conclude that the probate court erred by reading language into MCL 700.2114(4) that excludes after-born children. This subsection is not ambiguous because it does not conflict with other provisions of EPIC. I recognize that applying MCL 700.2114(4) in cases involving afterborn children may be difficult. But that the statute appears to be inconvenient is not a reason for this Court to avoid applying plain statutory language. Johnson v Recca, 492 Mich 169, 187; 821 NW2d 520 (2012). Accordingly, I conclude that MCL 700.2114(4) applies in all cases of intestate succession from a child to a natural parent, not exclusive of afterborn children.
However, this does not mean that Bierkle is correct that Ernest Umble’s claim is barred as a matter of law. Bierkle’s argument is premised on the presumption that a natural father cannot acknowledge or support an afterborn child. I reject this presumption and conclude that the probate court did not err by denying Bierkle’s motion for summary disposition.
*699As previously discussed, under MCL 700.2108, the probate court should consider a child who was in gestation at the time of a parent’s death as a living child throughout the period of gestation if the child lives 120 hours or more after birth. I therefore conclude that under MCL 700.2114(4), the probate court must determine whether the predeceased natural father failed to acknowledge or refused to provide support to the unborn child at the time of the father’s death. Accordingly, this issue cannot be resolved as a matter of law.
B. PERSUASIVE AUTHORITY
Additionally, because this is an issue of first impression in Michigan, this Court may consider cases from other jurisdictions as persuasive. See In re Turpening Estate, 258 Mich App 464, 466; 671 NW2d 567 (2003). Other jurisdictions hold that a natural father can acknowledge and provide support for a child even if the child dies before its birth. While this factual scenario is not directly analogous to a case involving an afterborn child, the crux of the argument—that it is impossible for the natural parent to acknowledge and support the child—is the same in both factual scenarios.
In In re Estate of Poole, 328 Ill App 3d 964; 263 Ill Dec 129; 767 NE2d 855 (2002), the Appellate Court of Illinois considered whether the acknowledged biological father of a fetus that was stillborn could inherit through the child. In that case, the Appellate Court of Illinois for the Third District considered whether statutory language providing that a father could not inherit through an illegitimate child unless the father, during the child’s lifetime, acknowledged the child, established a parental relationship with the child, and supported the child. Id. at 969. The maternal relatives *700in Poole argued that the father was not eligible to inherit because the child did not have a lifetime and so the father could not acknowledge her, support her, or establish a relationship with her. Id. The court determined that the father could qualify as an eligible parent because he resided with the child’s mother throughout the pregnancy, he provided financial and emotional support to the mother and through her to the unborn child, and he held himself out as the child’s father. Id. at 970.
Similarly, in Williams v Farmer, 876 So 2d 300; 2002 CA 02094 SCT (Miss, 2004), the Mississippi Supreme Court considered a statute providing that a father could not inherit through an illegitimate child unless the father openly treated the child as his own and had not refused or neglected to support the child. The father in Williams argued that this statute did not apply when his unborn child died in a car accident because it was impossible for him to comply with the statutory requirements. Id. at 302-303; 304-305. The court found that the statute did apply because the father could have acknowledged the fetus and provided support for it during the pregnancy. Id. at 305. The court barred the father from inheritance because he had no contact with the child’s mother while she was pregnant, and “did not contribute any support, financial or otherwise” to the mother during or after the pregnancy. Id. at 306.
I find these cases persuasive. They establish that, in other states with similar statutes, courts have found that it is not impossible for a natural father to acknowledge and support an unborn child.
c. application
In this case, the proofs are complicated by the passage of time. Carl Umble died in 1931. However, *701circumstantial evidence and inferences from the evidence may support the probate court’s findings. See Kupkowski v Avis Ford, Inc, 395 Mich 155, 166; 235 NW2d 324 (1975) (holding that circumstantial evidence and reasonable inferences may be sufficient to establish a fact).
Considering acknowledgment, the present state of the law in Colorado is that a father must consent to be named a father on a child’s birth certificate. See Colo Rev Stat 19-4-105(l)(c)(II). There is no evidence regarding the state of the law in Colorado at the time of Carl Koehler’s birth, but if similar laws existed, the fact that Carl Umble is listed on Carl Koehler’s birth certificate might provide evidence of acknowledgment. If the child was acknowledged in Carl Umble’s obituary, that too may be additional evidence.
I also note that there are many ways in which a father can support a child. See Turpening Estate, 258 Mich App at 468. The language of MCL 700.2114(4) states that the subsection applies if the parent refused to support the child. There must be some evidence that a natural parent refused to support his or her child. For instance, if another relative asked the natural father to support the child’s mother but the father denied that the child was his, this may be evidence of refusing to support the child. See Turpening Estate, 258 Mich App at 468. Similarly, a natural father’s lack of involvement in a pregnancy of which he was aware could provide circumstantial evidence to support an inference that the father refused to support the child. In contrast, if a natural father supported the unborn child by supporting its mother through the pregnancy or made provisions for familial support, this may be evidence that the predeceased father did in fact support the child. I note that a newspaper article provides *702evidence that Carl Umble was involved in an ongoing relationship with Florence Koehler until his death, to the point of striking a man who approached them during a kiss and getting into a fatal knife fight. I do not decide whether the evidence is sufficient to support an inference or finding on this point—I simply note that evidence may exist.
Because the probate court determined that MCL 700.2114(4) did not apply in this case, it did not receive evidence on either of these requirements. I would remand for additional proceedings.
VI. CONCLUSION
It may be difficult for the predeceased natural father of a child born out of wedlock to comply with MCL 700.2114(4), but the statute is not ambiguous, and the proofs are not impossible. MCL 700.2114(4) applies in cases involving the predeceased natural fathers of afterborn children. In such cases, the probate court must determine (1) whether the man was the child’s natural father, (2) whether the father acknowledged the unborn child, and (3) whether the father refused to support the unborn child.
I would reverse the probate court’s determination that MCL 700.2114(4) did not apply in this case and remand for further proceedings.
Ernest Umble is the only surviving paternal relative.
Pre-EPIC caselaw required the child-petitioner to show that he or she and his or her parent mutually acknowledged their relationship. See In re Scharenbroch Estate, 191 Mich App 215, 216; 477 NW2d 436 (1991); In re Jones Estate, 207 Mich App 544, 548; 525 NW2d 493 (1994).