Massachusetts Supreme Judicial Court

A.D. v. K.S. (And a Consolidated Case)

April 24, 2025

Summary

The court held that, after the statutory deadlines for rescinding or challenging a voluntary acknowledgment of parentage have expired, a Probate and Family Court judge generally may not use equitable authority to replace the acknowledged legal father with a genetically identified biological father who has no substantial relationship with the child. The statute of repose reflects a legislative judgment that finality of parentage determinations protects a child's stability, financial security, and legal rights, even when biology points elsewhere. The court vacated the judgments and remanded for proceedings consistent with its opinion.