exceptional circumstances test (Maryland) · Go Syfert
← Maryland issues

exceptional circumstances test in Maryland

14 Maryland opinions name it 2 courts 1997–2018 0 in the last five years

The cases below were cited by Maryland 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 (33)

CaseFollowedCited
Brandenburg v. LaBARREgreen
mdctspecapp · 2010 · cited in 2 Maryland opinions naming this issue, 2012–2014
2 sentences

2014This probably is enough to meet the exceptional circumstances standard under Brandenburg [ v. LaBarre, 193 Md.

2014This probably is enough to meet the exceptional circumstances standard under Brandenburg [v. LaBarre, 193 Md.App. 178 , 996 A.2d 939 (2010)] in order to overcome the burden with respect to Lance, however, the Court will also look to the traditional factors in determining exceptional circumstances, as developed in Ross v. Hoffman [, 280 Md. 172 , 372 A.2d 582 (1977)]. [A]t the time of the visitation hearing, Victoria had been away from the children approximately two years.

22
In Re Adoption No. A91-71Agreen
md · 1994 · cited in 2 Maryland opinions naming this issue, 2014–2018
2 sentences

2018There, the Court of Special Appeals explained that this Court had included a parent's behavior or character in the exceptional circumstances analysis in another case, In re Adoption/Guardianship No. A91-71A , 334 Md. 538 , 640 A.2d 1085 (1994).

2018There, the Court of Special Appeals explained that this Court had included a parent's behavior or character in the exceptional circumstances analysis in another case, In re Adoption/Guardianship No. A91-71A , 334 Md. 538 , 640 A.2d 1085 (1994).

12
Koshko v. Haininggreen
md · 2007 · cited in 2 Maryland opinions naming this issue, 2008–2009
2 sentences

2009It acknowledged that in Fairbanks it previously had held that visitation did not demand the enhanced protections embodied in the exceptional circumstances test that attend custody awards, id. at 429-30, 921 A.2d 171 but it made clear that this was no longer the case: There is no dispute that the grant or modification of visitation involves a lesser degree of intrusion on the fundamental right to parent than the assignment of custody.

2008The rationale for this distinction, as outlined in Fairbanks, was twofold: first, the plain text of the GVS did not require a threshold showing; and second, visitation was considered a “less weighty matter than outright custody of a child,” and therefore, it did not “demand the enhanced protections, embodied in the exceptional circumstances test, [attending] custody awards.” 330 Md. at 47-48 , 622 A.2d 121 ; see also Herrick v. Wain, 154 Md.App. 222, 231-32 , 838 A.2d 1263 (2003) (applying Fairbanks in a grandparent visitation dispute), overruled in part by Koshko, 398 Md. 404 , 921 A.2d 171 .

12
In Re Adoption/Guardianship of Alonza D.green
md · 2010 · cited in 1 Maryland opinions naming this issue, 2018–2018
2 sentences

2018See, e.g. , In re Adoption/Guardianship of Alonza D., Jr. , 412 Md. 442 , 462-63, 987 A.2d 536 (2010) ("Passage of time, without explicit findings that the continued relationship with [the parent] would prove detrimental to the best interests of the children, is not sufficient to constitute exceptional circumstances.").

2018See, e.g. , In re Adoption/Guardianship of Alonza D., Jr. , 412 Md. 442 , 462-63, 987 A.2d 536 (2010) ("Passage of time, without explicit findings that the continued relationship with [the parent] would prove detrimental to the best interests of the children, is not sufficient to constitute exceptional circumstances.").

11
Herrick v. Waingreen
mdctspecapp · 2003 · cited in 1 Maryland opinions naming this issue, 2008–2008
2 sentences

2008The rationale for this distinction, as outlined in Fairbanks, was twofold: first, the plain text of the GVS did not require a threshold showing; and second, visitation was considered a “less weighty matter than outright custody of a child,” and therefore, it did not “demand the enhanced protections, embodied in the exceptional circumstances test, [attending] custody awards.” 330 Md. at 47-48 , 622 A.2d 121 ; see also Herrick v. Wain, 154 Md.App. 222, 231-32 , 838 A.2d 1263 (2003) (applying Fairbanks in a grandparent visitation dispute), overruled in part by Koshko, 398 Md. 404 , 921 A.2d 171 .

2008The rationale for this distinction, as outlined in Fairbanks, was twofold: first, the plain text of the GVS did not require a threshold showing; and second, visitation was considered a “less weighty matter than outright custody of a child,” and therefore, it did not “demand the enhanced protections, embodied in the exceptional circumstances test, [attending] custody awards.” 330 Md. at 47-48 , 622 A.2d 121 ; see also Herrick v. Wain, 154 Md.App. 222, 231-32 , 838 A.2d 1263 (2003) (applying Fairbanks in a grandparent visitation dispute), overruled in part by Koshko, 398 Md. 404 , 921 A.2d 171 .

11
Wolinski v. Brownellergreen
mdctspecapp · 1997 · cited in 1 Maryland opinions naming this issue, 2007–2007
2 sentences

2007The Court in Fairbanks declared that, with regard to substantive due process rights, "[v]isitation is a considerably less weighty matter than outright custody of a child, and does not demand the enhanced protections, embodied in the exceptional circumstances test, that attend custody awards." Fairbanks, 330 Md. at 48 , 622 A.2d at 126 ; see also Wolinski, 115 Md.

2007App. at 305-06 , 693 A.2d at 39-40 .

11
Matter of Adoption of JJBgreen
nm · 1995 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Davis v. Collinsworthgreen
ky · 1989 · cited in 1 Maryland opinions naming this issue, 2005–2005
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Henderson v. Hendersongreen
mont · 1977 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Matter of KMgreen
mont · 1996 · cited in 1 Maryland opinions naming this issue, 2005–2005
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Dg v. Dmkgreen
sd · 1996 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Snyder v. Scheerergreen
wva · 1993 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
In Re Guardianship of Williamsgreen
kan · 1994 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Moore v. Mooregreen
sc · 1989 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
In Re Woodellgreen
nc · 1960 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Bailes v. Soursgreen
va · 1986 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
James v. Pretlowgreen
nc · 1955 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Wingerter v. Stategreen
ny · 1983 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Locklin v. Dukagreen
nev · 1996 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
White v. Thompsongreen
miss · 1990 · cited in 1 Maryland opinions naming this issue, 2005–2005
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Stockwell v. Stockwellgreen
idaho · 1989 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Matter of Guardianship of MRSgreen
okla · 1998 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Cotton v. Wisegreen
mo · 1998 · cited in 1 Maryland opinions naming this issue, 2005–2005
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Wilkerson v. Wilkersongreen
va · 1973 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
In Re Guardianship of DA McW.green
fla · 1984 · cited in 1 Maryland opinions naming this issue, 2005–2005
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Sider v. Sidergreen
md · 1994 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Petition of Kirchnergreen
ill · 1995 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
Ryan v. DeMellogreen
ri · 1976 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
In Re SBLgreen
vt · 1988 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Carvalho v. Lewisgreen
ga · 1981 · cited in 1 Maryland opinions naming this issue, 2005–2005
2 sentences

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

11
In Interest of EJHgreen
nd · 1996 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
In Re Adoption of Female Childgreen
tenn · 1995 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Troxel v. Granvillegreen
scotus · 2000 · cited in 1 Maryland opinions naming this issue, 2000–2000
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Fairbanks v. McCarter green
md · 1993
2 sentences

2009The Court concluded that the plain language of the GVS required neither a predicate showing of exceptional circumstances nor parental unfitness before an award of visitation to grandparents could be ordered, because “[visitation is a considerably less weighty matter than outright custody of a child, and does not demand the enhanced protections, embodied in the exceptional circumstances test, that attend custody awards.” Fairbanks, 330 Md. at 48 , 622 A.2d 121 .

2009The Court concluded that the plain language of the GVS required neither a predicate showing of exceptional circumstances nor parental unfitness before an award of visitation to grandparents could be ordered, because “[visitation is a considerably less weighty matter than outright custody of a child, and does not demand the enhanced protections, embodied in the exceptional circumstances test, that attend custody awards.” Fairbanks, 330 Md. at 48 , 622 A.2d 121 .

41997–2009
Ross v. Hoffman green
md · 1977
2 sentences

2017Although the Hoffman factors serve merely “as a guide” to aid a court in determining whether exceptional circumstances exist, see Hoffman, 280 Md. at 188 , 372 A.2d at 592 , we note that the Hoffman factors served as the analytical framework that the hearing judge relied on in ultimately finding that exceptional circumstances existed. 58 Accordingly, although we have previously acknowledged the existence of other factors that may be relevant in an exceptional circumstances inquiry, 59 we will confine our review of the hearing judge’s exceptional circumstances finding to his application of the

2017Although the Hoffman factors serve merely “as a guide” to aid a court in determining whether exceptional circumstances exist, see Hoffman, 280 Md. at 188 , 372 A.2d at 592 , we note that the Hoffman factors served as the analytical framework that the hearing judge relied on in ultimately finding that exceptional circumstances existed. 58 Accordingly, although we have previously acknowledged the existence of other factors that may be relevant in an exceptional circumstances inquiry, 59 we will confine our review of the hearing judge’s exceptional circumstances finding to his application of the

32010–2017
Aumiller v. Aumiller green
mdctspecapp · 2008
2 sentences

2014See Brandenburg, supra, 193 Md.App. 178 , 996 A.2d 939 (not considering harm to grandparents resulting from the denial of visitation); Aumiller, supra, 183 Md.App. 71 , 959 A.2d 849 (focusing on whether harm to minor children was caused by denial of visitation rather than harm to grandparents).

2014See Brandenburg, supra, 193 Md.App. 178 , 996 A.2d 939 (not considering harm to grandparents resulting from the denial of visitation); Aumiller, supra, 183 Md.App. 71 , 959 A.2d 849 (focusing on whether harm to minor children was caused by denial of visitation rather than harm to grandparents).

22012–2014
In Re Custody of HSHK green
wis · 1995
2 sentences

2000In determining whether one is a de facto parent, we employ the test enunciated in In re Custody of H.S.H.-K, 193 Wis.2d 649 , 533 N.W.2d 419 (1995), and V.C. v. M.J.B., 163 N.J. 200 , 748 A.2d 539 (2000).

2000In determining whether one is a de facto parent, we employ the test enunciated in In re Custody of H.S.H.-K, 193 Wis.2d 649 , 533 N.W.2d 419 (1995), and V.C. v. M.J.B., 163 N.J. 200 , 748 A.2d 539 (2000).

22000–2000
Vc v. Mjb green
nj · 2000
2 sentences

2000In determining whether one is a de facto parent, we employ the test enunciated in In re Custody of H.S.H.-K, 193 Wis.2d 649 , 533 N.W.2d 419 (1995), and V.C. v. M.J.B., 163 N.J. 200 , 748 A.2d 539 (2000).

2000In determining whether one is a de facto parent, we employ the test enunciated in In re Custody of H.S.H.-K, 193 Wis.2d 649 , 533 N.W.2d 419 (1995), and V.C. v. M.J.B., 163 N.J. 200 , 748 A.2d 539 (2000).

22000–2000
Pastore v. Sharp green
mdctspecapp · 1989
1 sentence

2018For example, in Ta'Niya C. , 417 Md. at 104 n.11, 8 A.3d 745 , we explained that in a TPR exceptional circumstances analysis, "[i]n addition to ... statutory factors, courts may consider 'such parental characteristics as age, stability, and the capacity and interest of a parent to provide for the emotional, social, moral, material, and educational needs of the child.' " (quoting Pastore v. Sharp , 81 Md.

12018–2018
In Re Adoption/Guardianship of Ta'Niya C. green
md · 2010
2 sentences

2018For example, in Ta'Niya C. , 417 Md. at 104 n.11, 8 A.3d 745 , we explained that in a TPR exceptional circumstances analysis, "[i]n addition to ... statutory factors, courts may consider 'such parental characteristics as age, stability, and the capacity and interest of a parent to provide for the emotional, social, moral, material, and educational needs of the child.' " (quoting Pastore v. Sharp , 81 Md.

2018For example, in Ta'Niya C. , 417 Md. at 104 n.11, 8 A.3d 745 , we explained that in a TPR exceptional circumstances analysis, "[i]n addition to ... statutory factors, courts may consider 'such parental characteristics as age, stability, and the capacity and interest of a parent to provide for the emotional, social, moral, material, and educational needs of the child.' " (quoting Pastore v. Sharp , 81 Md.

12018–2018
In re: Adoption of K'amora K. green
mdctspecapp · 2014
1 sentence

2018K'Amora K. , 218 Md.

12018–2018
Janice M. v. Margaret K. red
md · 2008
2 sentences

2008Janice M, 404 Md. at 693-95 , 948 A.2d 73 .

2008Janice M, 404 Md. at 693-95 , 948 A.2d 73 .

12008–2008
In re the Estate, Conservatorship, & Guardianship of K.M. green
mont · 1996
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

12005–2005
Alford v. Thomas green
okla · 1957
12005–2005
Merritt v. Way green
ny · 1983
12005–2005
In re S.B.L. green
vt · 1988
1 sentence

2005McW, 460 So.2d 368, 370 (Fla.1984) (stating parental presumption can be rebutted only if ‘detrimental to the welfare of the child’ based on an exceptional circumstances test); Carvalho v. Lewis, 247 Ga. 94 , 274 S.E.2d 471, 472 (1981) (applying unfitness or ‘compelling circumstances’ test and noting ‘[a] court is not allowed to terminate a parent’s natural right because it has determined that the child might have better financial, educational, or even moral advantages elsewhere’); Stockwell v. Stockwell, 116 Idaho 297 , 775 P.2d 611, 613 (1989) (requiring unfitness, abandonment, or that ‘the c

12005–2005

Statutes the citing opinions construe

MD § Md. Code Ann., Fam. Law § 9-102 (6) MD § Md. Code Ann., Cts. & Jud. Proc. § 3-801 (3) MD § Md. Code Ann., Fam. Law § 5-323 (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

UT 51 (1993–2026) CT 26 (1981–2013) NJ 24 (1964–2026) MD 14 (1997–2018) NY 11 (1989–2015) LA 8 (2013–2024) PA 6 (1967–2020) TN 4 (2010–2024) MO 4 (1996–2025) OH 3 (2002–2008) KS 3 (2009–2021) ND 2 (2010–2010) TX 2 (1985–2015) MI 2 (1989–2014) WI 2 (2017–2017) CA 2 (2002–2021) GA 2 (2006–2013)

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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