In re Custody of B.M.H.

Michael Holt (plaintiff), who had a child, C.H., with Laurie during a prior relationship, supported Laurie throughout her subsequent pregnancy with B.M.H. after B.M.H.'s biological father died, married Laurie shortly after B.M.H.'s birth before later divorcing her, and was highly active in B.M.H.'s life, holding himself out as her father in every respect while Laurie changed B.M.H.'s last name to Holt and agreed B.M.H. would follow the same custody arrangement as C.H. When Laurie planned to move 50 miles away, Michael petitioned for non-parental custody and de facto parentage of B.M.H.; the trial court initially found a prima facie de facto parentage case but, after the Washington Supreme Court's intervening decision in In re Parentage of M.F. addressing a former stepfather's de facto parentage claim, dismissed Michael's de facto parentage claim while still finding good cause to proceed on the non-parental custody petition. The court of appeals reinstated the de facto parentage claim, and the Washington Supreme Court granted review.