Gardner v. Greenlaw
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The Supreme Judicial Court vacated the judgment of the district court dismissing with prejudice Grandmother's complaints for determination of de facto parentage concerning her two minor grandchildren, holding that the best interests determinations required in guardianship actions and in actions for de facto parentage are distinct determinations.
The district court determined that issue preclusion completely barred Grandmother's claims for de facto parentage because the issue of the child's best interests was already decided in a prior consolidated proceeding on competing guardianship petitions. The Supreme Court vacated the judgment below and remanded the matter for the court to consider Grandmother's standing with respect to her complaints for de facto parentage, holding that issue preclusion did not prevent the court from considering Grandmother's complaints for de facto parentage because the best interests determinations required in a guardianship proceeding are not identical to those in a proceeding for de facto parentage.
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