Mich. Comp. Laws » Michigan Compiled Laws / Chapter 700 / Act 386 of 1998
Michigan Compiled Laws

Mich. Comp. Laws § 700.2114 (2026)

Parent and child relationship.

✓ current as of July 2026
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ESTATES AND PROTECTED INDIVIDUALS CODE


Act 386 of 1998


700.2114 Parent and child relationship.

Sec. 2114.

    (1) Except as provided in subsections (2) to (4), for purposes of intestate succession by, through, or from an individual, an individual is the child of the individual's natural parents, regardless of their marital status. The parent and child relationship may be established and the individual may be considered a child of the individual's natural parent in any of the following manners:

    (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession. If 2 individuals participated in a marriage ceremony in apparent compliance with the law before the birth of a child, even though the attempted marriage may be void, the child is presumed to be their child for purposes of intestate succession.

    (b) If a child is born out of wedlock or if a child is born or conceived during a marriage but is not the issue of that marriage, an individual who did not give birth is considered to be the child's natural parent for purposes of intestate succession if any of the following occur:

    (i) The individual who did not give birth joins with the child's mother and acknowledges that child as his child by completing an acknowledgment of parentage as prescribed in the acknowledgment of parentage act, 1996 PA 305, MCL 722.1001 to 722.1013.

    (ii) The individual who did not give birth joins the mother in a written request for a correction of certificate of birth pertaining to the child that results in issuance of a substituted certificate recording the child's birth.

    (iii) The individual who did not give birth and child have established a mutually acknowledged relationship of parent and child that begins before the child becomes age 18 and continues until terminated by the death of either.

    (iv) The individual who did not give birth is determined to be the child's parent and an order of filiation establishing that paternity or parentage is entered as provided in the paternity act, 1956 PA 205, MCL 722.711 to 722.730.

    (v) Regardless of the child's age or whether or not the individual with a claim to parentage has died, the court with jurisdiction over probate proceedings relating to the decedent's estate determines that the individual who did not give birth is the child's parent, using the standards and procedures established under the paternity act, 1956 PA 205, MCL 722.711 to 722.730, or other law of this state.

    (vi) The individual who did not give birth is determined to be the parent in an action under the revocation of parentage act, 2012 PA 159, MCL 722.1431 to 722.1445.

    (c) A child who is not conceived or born during a marriage is an individual born in wedlock if the child's parents marry after the conception or birth of the child.

    (d) A child conceived by assisted reproduction with the consent of an individual consistent with the assisted reproduction and surrogacy parentage act is considered the child of the intended parent or parents for purposes of intestate succession.

    (e) A child conceived by assisted reproduction under a surrogacy agreement that complies with the assisted reproduction and surrogacy parentage act is considered the child of the intended parent or parents for purposes of intestate succession.

    (2) An adopted individual is the child of the child's adoptive parent or parents and not of the child's natural parents, but adoption of a child by the spouse of either natural parent has no effect on either the relationship between the child and that natural parent or the right of the child or a descendant of the child to inherit from or through the other natural parent. An individual is considered to be adopted for purposes of this subsection when a court of competent jurisdiction enters an interlocutory decree of adoption that is not vacated or reversed.

    (3) The permanent termination of parental rights of a minor child by an order of a court of competent jurisdiction; by a release for purposes of adoption given by the parent, but not a guardian, to the department of health and human services or a licensed child placement agency, or before a probate or juvenile court; 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.

    (4) Inheritance from or through a child by either natural parent or the child's kindred is precluded unless that natural parent has openly treated the child as the natural parent's child and has not refused to support the child.

    

History: 1998, Act 386, Eff. Apr. 1, 2000 ;-- Am. 2000, Act 54, Eff. Apr. 1, 2000 ;-- Am. 2004, Act 314, Eff. Sept. 1, 2004 ;-- Am. 2012, Act 160, Imd. Eff. June 12, 2012 ;-- Am. 2024, Act 27, Eff. Apr. 2, 2025

PopularName Notes:

EPIC
Notes of Decisions
Cited in 26 cases (7 in the last 5 years), 2003–2023 · leading case: in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016).
Sort: Relevance Newest Treatment
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). · cites it 106× “MCL 700.2114 states in relevant part: (1) 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.”
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). · cites it 21× “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
Aichele v. Hodge, 673 N.W.2d 452 (Mich. Ct. App. 2004). · cites it 10× “MCL 700.2114 provides: (1) 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.”
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). · cites it 19× “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
in Re Certified Question (Mattison v. Soc SEC), 825 N.W.2d 566 (Mich. 2012). · cites it 13× “MCL 700.2114 describes various ways in which “[t]he parent and child relationship” may be established in order to show that a claimant is a descendant of a 2 survived their father.”
Kaiser v. Schreiber, 670 N.W.2d 697 (Mich. Ct. App. 2003). · cites it 8× “§ 700.2114(1)(a), which is part of the Estates and Protected Individuals Code (EPIC), M.”
In Re Kh, 677 N.W.2d 800 (Mich. 2004). · cites it 2× “) See also MCL 700.2114(1)(a) ("If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for the purposes of intestate succession.”
In Re Turpening Est., 671 N.W.2d 567 (Mich. Ct. App. 2003). · cites it 5× “This case arises out of a dispute between petitioner, decedent’s mother, and respondent over the interpretation of MCL 700.2114(4) and respondent’s right to inherit from decedent.”
People v. Zajaczkowski, 825 N.W.2d 554 (Mich. 2012). · cites it 2× “9 See MCL 700.2114(1)(a); MCL 700.2114(5). 10 Zajaczkowski, 293 Mich App at 377 .”
Heather Martin Gartner & Melissa Gartner, Individually & as Next Friends of Mackenzie Jean Gartner, a Minor Child v. Iowa Dep't of Pub. Health, 830 N.W.2d 335 (Iowa 2013). · cites it 2× “”); Mich. Comp. Laws Ann. § 700.2114 (1)(a) (West 2012) (“If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
People v. Zajaczkowski, 810 N.W.2d 627 (Mich. Ct. App. 2011). · cites it 3× “” MCL 700.2114(5). Here, because defendant was conceived and born during his mother’s marriage to the victim’s father, the strong presumption of legitimacy arose.”
People v. Wambar, 831 N.W.2d 891 (Mich. Ct. App. 2013). “” In the context of intestate succession, MCL 700.2114(3) states that “[t]he permanent termination of parental rights of a minor child by an order of *127 a court of competent jurisdiction .”
Show all 26 citing cases →
— Mich. Comp. Laws § 700.2114(1) — 4 cases
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
in Re Koehler Est. (Mich. Ct. App. 2016).
Jeremy Phillip Jones v. Sharon Denise Jones (Mich. Ct. App. 2017).
— Mich. Comp. Laws § 700.2114(1)(a) — 11 cases
in Re Certified Question (Mattison v. Soc SEC), 825 N.W.2d 566 (Mich. 2012). “MCL 700.2114 describes various ways in which “[t]he parent and child relationship” may be established in order to show that a claimant is a descendant of a 2 survived their father.”
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
Kaiser v. Schreiber, 670 N.W.2d 697 (Mich. Ct. App. 2003). “§ 700.2114(1)(a), which is part of the Estates and Protected Individuals Code (EPIC), M.”
In Re Kh, 677 N.W.2d 800 (Mich. 2004). “) See also MCL 700.2114(1)(a) ("If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for the purposes of intestate succession.”
People v. Zajaczkowski, 825 N.W.2d 554 (Mich. 2012). “9 See MCL 700.2114(1)(a); MCL 700.2114(5). 10 Zajaczkowski, 293 Mich App at 377 .”
— Mich. Comp. Laws § 700.2114(1)(b) — 3 cases
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
in Re Koehler Est. (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 700.2114(1)(b)(c) — 1 case
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(1)(b)(i) — 1 case
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(1)(b)(iii) — 2 cases
in Re Ward Est. (Mich. Ct. App. 2016).
Kyresha Lefever v. Lanesha Matthews (Mich. Ct. App. 2021).
— Mich. Comp. Laws § 700.2114(1)(b)(v) — 3 cases
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
In Re Seybert Est. (Mich. Ct. App. 2022).
in Re Koehler Est. (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 700.2114(1)(c) — 1 case
Aichele v. Hodge, 673 N.W.2d 452 (Mich. Ct. App. 2004). “MCL 700.2114 provides: (1) 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.”
— Mich. Comp. Laws § 700.2114(3) — 3 cases
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
People v. Wambar, 831 N.W.2d 891 (Mich. Ct. App. 2013). “” In the context of intestate succession, MCL 700.2114(3) states that “[t]he permanent termination of parental rights of a minor child by an order of *127 a court of competent jurisdiction .”
in Re Koehler Est. (Mich. Ct. App. 2016).
— Mich. Comp. Laws § 700.2114(4) — 4 cases
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
In Re Turpening Est., 671 N.W.2d 567 (Mich. Ct. App. 2003). “This case arises out of a dispute between petitioner, decedent’s mother, and respondent over the interpretation of MCL 700.2114(4) and respondent’s right to inherit from decedent.”
in Re Koehler Est. (Mich. Ct. App. 2016).
in Re Koehler Est. (Mich. 2017).
— Mich. Comp. Laws § 700.2114(5) — 6 cases
People v. Zajaczkowski, 825 N.W.2d 554 (Mich. 2012). “9 See MCL 700.2114(1)(a); MCL 700.2114(5). 10 Zajaczkowski, 293 Mich App at 377 .”
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
People v. Zajaczkowski, 810 N.W.2d 627 (Mich. Ct. App. 2011). “” MCL 700.2114(5). Here, because defendant was conceived and born during his mother’s marriage to the victim’s father, the strong presumption of legitimacy arose.”
People of Michigan v. John Antonya Moss (Mich. 2022).
People of Michigan v. John Antonya Moss (Mich. 2022).
— Mich. Comp. Laws § 700.2114(b) — 1 case
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(b)(u) — 1 case
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
— Mich. Comp. Laws § 700.2114(b)(v) — 1 case
In re Casey Est., 856 N.W.2d 556 (Mich. Ct. App. 2014). “Because Renee and Bruce claim to be interested persons as the biological children of the decedent, the parties focused their attention on MCL 700.2114, which sets forth the framework for establishing the parent-child relationship for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(c) — 1 case
KIENUTSKE v. Barnhart, 375 F. Supp. 2d 556 (E.D. Mich. 2004).
— Mich. Comp. Laws § 700.2114(l)(a) — 5 cases
Kaiser v. Schreiber, 670 N.W.2d 697 (Mich. Ct. App. 2003). “§ 700.2114(1)(a), which is part of the Estates and Protected Individuals Code (EPIC), M.”
In Re Kh, 677 N.W.2d 800 (Mich. 2004). “) See also MCL 700.2114(1)(a) ("If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for the purposes of intestate succession.”
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
People v. Zajaczkowski, 810 N.W.2d 627 (Mich. Ct. App. 2011). “” MCL 700.2114(5). Here, because defendant was conceived and born during his mother’s marriage to the victim’s father, the strong presumption of legitimacy arose.”
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
— Mich. Comp. Laws § 700.2114(l)(b) — 2 cases
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
— Mich. Comp. Laws § 700.2114(l)(b)(i) — 1 case
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(l)(b)(ic) — 1 case
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(l)(b)(ii) — 1 case
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(l)(b)(iii) — 1 case
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(l)(b)(u) — 1 case
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
— Mich. Comp. Laws § 700.2114(l)(b)(ui) — 1 case
In re Daniels Est., 837 N.W.2d 1 (Mich. Ct. App. 2013). “The parent and child relationship may be established in any of the following manners: (a) If a child is born or conceived during a marriage, both spouses are presumed to be the natural parents of the child for purposes of intestate succession.”
— Mich. Comp. Laws § 700.2114(l)(b)(ü) — 1 case
in Re Koehler Est., 314 Mich. App. 667 (Mich. Ct. App. 2016). “MCL 700.2114 states in relevant part: (1) 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.”
— Mich. Comp. Laws § 700.2114(l)(c) — 1 case
Aichele v. Hodge, 673 N.W.2d 452 (Mich. Ct. App. 2004). “MCL 700.2114 provides: (1) 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.”
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