<!-- citation-library:start --> ## Citation reference Donovan L., In re (2016) 244 Cal.App.4th 1075, 198 Cal.Rptr.3d 550 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end --> <!-- reviewed-cases-031-050:start --> ## Holding Biological parentage alone did not justify the third-parent finding in the dependency proceeding. The court required a qualifying parentage claim and, for the section 7612(c) determination at issue, an existing parent-child relationship whose loss would make recognizing only two parents detrimental. It reversed the third-parent finding and associated services and visitation. > [!note] Scope and later law > Distinguish biological, presumed, and conclusively presumed parentage. A general best-interests finding is not a substitute for the applicable statutory requirements. [[Codes & Rules/Family Code/Division 12 - Parent and Child Relationship (§§ 7500 – 7962)/Part 3 - Uniform Parentage Act (§§ 7600 - 7730)/Chapter 2 - Establishing Parent and Child Relationship (§§ 7610 - 7614)/Cal. Fam. Code § 7611|Cal. Fam. Code § 7611]] [[Codes & Rules/Family Code/Division 12 - Parent and Child Relationship (§§ 7500 – 7962)/Part 3 - Uniform Parentage Act (§§ 7600 - 7730)/Chapter 2 - Establishing Parent and Child Relationship (§§ 7610 - 7614)/Cal. Fam. Code § 7612|Cal. Fam. Code § 7612]] Original paraphrase based on the court opinion, checked October 25, 2026. Subsequent treatment has not been comprehensively checked. <!-- reviewed-cases-031-050:end -->