Michelle A. Gardner v. Leslie Greenlaw

Summary

The court held that issue preclusion did not completely bar the grandmother's de facto parentage complaints because the best-interests inquiry in a guardianship proceeding is not identical to the inquiry required for de facto parentage. It nevertheless held that issue preclusion limits any later award of parental rights and responsibilities by preserving the prior determinations concerning the children's primary residence and decision-making authority. The judgment was vacated and the matter remanded for consideration of the grandmother's standing and, if established, further proceedings under the governing statute.