MARK MALKIN AND STEVEN M. WISE, ETC.
v.
FABIANA CORREA PLA

Fla. 3d DCA | 2022-07-06
No. 22-0794
Barry, Craig, Crumlish, Doyle, MacPhail, Rogers, Williams
Florida District Court of Appeal, Third District (2022)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

In a custody dispute between a natural parent and a third party, custody can be denied to the parent only when supported by clear and convincing evidence of abandonment, unfitness, or detriment to the child's welfare.


Headnotes

[1] Custody can be denied to a natural parent in a dispute with a third party only upon clear and convincing evidence of abandonment, unfitness, or detriment to the child's w…

[2] Individuals claiming parentage on grounds other than biology or legal status do not possess the same rights as biological or legal parents.

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Key Quotes

“[I]n a custody dispute between a natural parent and a third party (including grandparents), custody can be denied to the parent only when supported by clear and convincing evidence establishing that the parent has abandoned the child or is in some other meaningful sense an unfit parent, or that placing the child with the parent will be detrimental to the child's welfare.”

Murphy v. Markham-Crawford, 665 So. 2d 1093, 1094 (Fla. 1st DCA 1995)

Facts & Procedural History

The case involves a custody dispute between natural parent(s) and a third party. The trial court issued a non-final order addressing custody or visita…

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Opinion of the Court

PER CURIAM.

Affirmed. See Murphy v. Markham-Crawford, 665 So. 2d 1093, 1094 (Fla. 1st DCA 1995) (“[I]n a custody dispute between a natural parent and a third party (including grandparents), custody can be denied to the parent only when supported by clear and convincing evidence establishing that the parent has abandoned the child or is in some other meaningful sense an unfit parent, or that placing the child with the parent will be detrimental to the child’s welfare.”); Russell v. Pasik, 178 So. 3d 55, 59 (Fla. 2d DCA 2015) (“[T]hose who claim parentage on some basis other than biology or legal status do not have the same rights, including the right to visitation, as the biological or legal parents.”); Lane-hepburn v. Hepburn, 290 So. 3d 589, 590 (Fla. 2d DCA 2020) (noting section 61.13, Florida Statutes, applies only to parents’ rights and “‘does not extend to nonparents.’” (quoting Russell, 178 So. 3d at 59.)); LiFleur v. Webster, 138 So. 3d 570, 574 (Fla. 3d DCA 2014) (“[A] trial court cannot engage in a ‘best interests of the child’ analysis unless and until there is sufficient proof to establish parental unfitness or substantial threat of significant and demonstrable harm to the child.”).


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