Conover v. Conover

Michelle and Brittany Conover (plaintiff and defendant) conceived their son Jaxon through artificial insemination before marrying, married when Jaxon was six months old, and separated a year later; after Brittany cut off Michelle's visitation, Michelle sought visitation, but the trial court held she lacked standing because Jaxon was born before the marriage, relying on prior precedent (Janice M.) holding de facto parents must proceed as ordinary third parties. The appellate court affirmed, and Michelle appealed, urging recognition of de facto parent standing.