J.M. v. C.G.

Summary

The court affirmed the denial of M.H.'s motion to intervene and the dismissal of his statutory and equitable parentage complaints. It held that M.H.'s challenge to the voluntary acknowledgment of parentage was barred by the one-year statute of repose, and that his equitable claim could proceed only if he first established a substantial parent-child relationship by clear and convincing evidence, which he failed to do. The court also concluded that the availability of the equitable claim resolved M.H.'s due process argument without requiring a constitutional ruling.