Father challenge (Massachusetts) · Go Syfert
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Father challenge in Massachusetts

16 Massachusetts opinions name it 2 courts 1947–2026 9 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Adoption of Gretagreen
mass · 2000 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025See Adoption of Greta, 431 Mass. 577, 587 (2000) (judge's findings of fact will not be set aside unless clearly erroneous). 9 Rather, the record shows that the father sent one of the parents' younger children away to live with the father's ex- girlfriend for two years; at most, Kalil had lived with the father for only two months; and that it was the mother who was the primary caretaker for their children, and when she was overwhelmed with their care, rather than turn to the father for help, she moved to Georgia to seek assistance from her mother. 10 father argues that the judge did not careful

11
Adoption of Dianegreen
mass · 1987 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024We are not persuaded that the evidence of the father's domestic violence and anger management issues was stale, see Adoption of Diane, 400 Mass. 196, 204 (1987); we likewise consider it sufficiently detailed to support the judge's subsidiary findings concerning the mother's ability to protect 16Tellingly, the father does not challenge the judge's findings that although the mother testified that she did not want the father to supervise Zygmunt "because she wants Zygmunt to be safe and not to be hurt again," and her safety plan for the family included taking the children to a friend's house when

11
Custody of Two Minorsgreen
mass · 1986 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024Cf. id. at 617 (holding privilege against self-incrimination is not applicable in child custody case).

11
Dongreen
mass · 2001 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
1 sentence

2023Rather, he challenges the findings pertaining only to the mother, as his position at trial was that the children should be reunified with the mother; his position remains the same on appeal. 3 The judge made 318 findings of fact and thirty-five conclusions of law that "are both specific and detailed, demonstrating, as we require, that close attention was given to the evidence." Adoption of Don, 435 Mass. 158, 165 (2001). 4 The judge noted that the 51A reports are "not taken for the truth of the matter asserted, but merely to explain why DCF became involved, i.e., to set the stage." See Custody

11
Custody of Michelgreen
massappct · 1990 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
1 sentence

2023Rather, he challenges the findings pertaining only to the mother, as his position at trial was that the children should be reunified with the mother; his position remains the same on appeal. 3 The judge made 318 findings of fact and thirty-five conclusions of law that "are both specific and detailed, demonstrating, as we require, that close attention was given to the evidence." Adoption of Don, 435 Mass. 158, 165 (2001). 4 The judge noted that the 51A reports are "not taken for the truth of the matter asserted, but merely to explain why DCF became involved, i.e., to set the stage." See Custody

11
Cooper v. Coopergreen
massappct · 2004 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
1 sentence

2023"When the judgment to be modified incorporates 6 This attributed income amount was based on the mother's capacity to earn $15 per hour working forty hours per week, which the mother conceded, and the father did not challenge, at trial. 5 an agreement of the parties, we have said that, notwithstanding that the agreement does not survive the judgment as a binding contract, we nevertheless will 'review the findings to determine whether the judge gave appropriate consideration to the parties' intentions as expressed in their written agreement, . . . and to any changes in their circumstances since

11
Adoption of Marygreen
mass · 1993 · cited in 1 Massachusetts opinions naming this issue, 2023–2023
1 sentence

2023See Adoption of Mary, 414 Mass. 705, 710 (1993). b.

11
Care and Protection of Vickgreen
massappct · 2016 · cited in 1 Massachusetts opinions naming this issue, 2017–2017
1 sentence

2017See Care & Protection of Vick, 89 Mass. App. Ct. 704, 706 (2016).

11
Care & Protection of Georgettegreen
mass · 2003 · cited in 1 Massachusetts opinions naming this issue, 2010–2010
1 sentence

2010See Care & Protection of Georgette, 439 Mass. at 33 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Adoption of Vito green
mass · 2000
2 sentences

2018The purpose of postadoption visitation "is not to strengthen the bonds between the child and h[er] biological mother or father, but to assist the child as [s]he negotiates ... the tortuous path from one family to another." Adoption of Vito , 431 Mass. 550 , 564-565 (2000).

2009In Adoption of Vito, 431 Mass. 550 (2000), this court discussed at some length the equitable power of a judge to order posttermination and postadoption contact, including visitation, between a child and his biological parents, id. at 556-558 , while also recognizing that there are limits to that power.

22009–2018
Custody of Eleanor green
mass · 1993
1 sentence

2026Because the father does not challenge any of the judge's factual findings as clearly erroneous, we address only whether "the judge's findings prove parental unfitness by clear and convincing evidence." Custody of Eleanor, 414 Mass. at 801 .

12026–2026
ADOPTION OF KNOX. green
massappct · 2023
1 sentence

2026Adoption of Knox, supra. The father does not challenge the department's regulation as ultra vires.10 To the extent that the father argues that the 10 department's regulation infringes on the father's constitutional right to travel, we are not persuaded. "[A]pplication of the 19 The judge found that by the end of the first trial in 2023, the father was aware of the identified risks that supported a finding of unfitness, including that the ICPC home plan denial was a barrier to placing Farhina in his custody.

12026–2026
Huddleston v. Huddleston green
massappct · 2001
1 sentence

2023"When the judgment to be modified incorporates 6 This attributed income amount was based on the mother's capacity to earn $15 per hour working forty hours per week, which the mother conceded, and the father did not challenge, at trial. 5 an agreement of the parties, we have said that, notwithstanding that the agreement does not survive the judgment as a binding contract, we nevertheless will 'review the findings to determine whether the judge gave appropriate consideration to the parties' intentions as expressed in their written agreement, . . . and to any changes in their circumstances since

12023–2023
L.L., a juvenile v. Commonwealth green
mass · 2014
1 sentence

2023L.L. v. Commonwealth, 470 Mass. 169 , 185 n. 27 (2014). 2.

12023–2023
Adoption of Katharine green
massappct · 1997
1 sentence

2021In ascertaining parental fitness, the judge "may consider past conduct to predict future ability and performance." Adoption of Katharine, supra at 32–33. 6 Although the grandparents purport to join the father and Jacob in arguing that the department's adoption plan was inadequate, they were not parties to the care and protection proceedings and, therefore, do not have standing to appeal from that aspect of the decision. 7 The father does not challenge the judge's finding that he was unfit or the termination of his parental rights. 8 a.

12021–2021
Custody of Victoria green
mass · 2015
1 sentence

2020Finally, under § 2 (a) (4), appropriate forum jurisdiction "allows Massachusetts courts to exercise jurisdiction over custody if (i) no other State would have jurisdiction under any of the first three paragraphs or another State has 'declined to exercise jurisdiction on the ground that the [C]ommonwealth is the more appropriate forum to determine the custody of the child,' and (ii) it is in the 'best interest of the child' for Massachusetts to assume jurisdiction." Custody of Victoria, 473 Mass. at 71-72 , quoting G.

12020–2020
Dunn v. Dunn green
michctapp · 1981
1 sentence

1995Other decisions that are concerned with the question of voluntary retirement to meet spiritual obligations include Dunn v. Dunn, 105 Mich. App. 793 (1981), and McKeever v. McKeever, 36 Or.

11995–1995
In re the Dissolution of the Marriage of McKeever neutral
orctapp · 1978
1 sentence

1995Other decisions that are concerned with the question of voluntary retirement to meet spiritual obligations include Dunn v. Dunn, 105 Mich. App. 793 (1981), and McKeever v. McKeever, 36 Or.

11995–1995
Thurman's Case green
mass · 1927
1 sentence

1947Thurman’s Case, 259 Mass. 222 .

11947–1947

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 119, § 51A (5) MA § Mass. Gen. Laws ch. 210, § 3 (5) MA § Mass. Gen. Laws ch. 119, § 26 (3) MA § Mass. Gen. Laws ch. 209B, § 1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 387 (1868–2026) CA 149 (1924–2026) IN 141 (1925–2026) TX 123 (1972–2026) MO 122 (1919–2025) OH 110 (1905–2026) AZ 86 (2011–2026) NY 64 (1924–2026) TN 52 (1980–2026) UT 46 (1987–2026) OK 39 (1985–2026) IA 34 (2009–2026) NM 30 (1993–2024) WY 28 (2000–2025) AL 24 (1966–2025) VA 21 (1985–2025) SC 21 (1936–2025) NC 18 (2002–2025) FL 18 (1957–2025) GA 18 (1911–2025) WV 17 (1895–2026) MA 16 (1947–2026) HI 13 (1970–2026) IL 13 (1956–2026) ME 12 (1830–2022) KS 11 (1995–2025) MD 10 (2006–2025) KY 10 (2011–2026) DE 7 (2015–2024) MT 7 (2017–2025) CO 7 (2011–2025) ID 6 (1961–2022) VT 6 (1911–2024) OR 6 (1971–2017) WA 6 (1984–2023) LA 6 (1981–2022) MS 5 (1994–2009) MI 5 (1988–2015) SD 4 (1993–2024) MN 4 (1915–2003) CT 3 (2009–2021) NE 2 (1985–2020) DC 2 (1990–2013) NH 2 (1989–2021) WI 2 (1939–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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