Kelly Oscar and Jack Oscar v. Larry Lafferty

Summary

The Court affirmed the Family Court’s determination that Larry Lafferty could establish parentage outside the two-year limitations period because the presumed father, Jack Oscar, never openly held Audrey out as his own. The Court held that “never” requires consideration of the entire relevant period, not merely the two years after birth, and that “openly held out” means publicly representing the child as one’s own. Although the Family Court initially focused on the two-year period, its factual findings supported the ultimate conclusion that Oscar had not publicly represented Audrey as his daughter.