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## 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.
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## 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.
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