Stevens v. Griggs
362 P.3d 662, 2013 OK CIV APP 104 (2013)
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Rule of Law:
Under the Oklahoma Uniform Parentage Act, a legal action to adjudicate the parentage of a child with a presumed father must be commenced within two years of the child's birth. This statute of limitations is based on a strong public policy of protecting the parent-child relationship within a marriage and cannot be waived or tolled by the private conduct or agreements of the mother and an alleged biological father.
Facts:
- Tabitha Stevens and Freddie Griggs maintained an ongoing sexual relationship while both were married to other individuals.
- In March 2006, Tabitha gave birth to a child, CRS, during her marriage to her Husband.
- Tabitha's Husband believed he was CRS's father, lived with the child, and held him out as his son for the first five years of the child's life.
- Shortly after the birth, Tabitha and Freddie obtained a 'mail order' DNA test, which led them to believe Freddie was the biological father.
- Tabitha and Freddie agreed to keep Freddie's alleged paternity a secret, though Freddie acknowledged the child to his family and provided some informal support.
- Five years after the child's birth, Tabitha's Husband learned of the situation from an anonymous note left on his truck, which led to his separation from Tabitha.
- Following the separation, Tabitha's Husband wanted nothing more to do with the child, and Freddie failed to meet Tabitha's demands for financial support.
Procedural Posture:
- In June 2011, Tabitha Stevens's application for child support services against Freddie Griggs was denied by the state because the child had a presumed legal father.
- In March 2012, Tabitha Stevens filed a Petition to Establish Paternity against Freddie Griggs in the Oklahoma district court (trial court).
- Freddie Griggs filed a motion to dismiss the petition.
- Following an evidentiary hearing, the district court granted the motion and dismissed Tabitha's petition.
- Tabitha Stevens (Appellant) appealed the district court's dismissal to the Oklahoma Court of Civil Appeals (intermediate appellate court).
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Issue:
Does the Oklahoma Uniform Parentage Act's two-year statute of limitations bar a mother's action to establish paternity against an alleged biological father when the action is filed six years after the child's birth and the child was born during the mother's marriage to another man who is the presumed father?
Opinions:
Majority - P. Thomas Thornbrugh
Yes. A mother's action to establish paternity is barred if not commenced within two years of the child's birth when the child has a presumed father under the Oklahoma Uniform Parentage Act. The court reasoned that the Act creates a legal presumption that a man is a child's father if the child is born during his marriage to the mother. This presumption, which applies to Tabitha's Husband, can only be rebutted by a legal action commenced within two years of the child's birth, per § 7700-607. Tabitha filed this action six years late. The court rejected Tabitha's argument that Freddie's conduct should equitably toll the statute of limitations, citing Clark v. Edens for the proposition that the presumption of paternity is a matter of public policy for the benefit of the child and cannot be waived by the private actions of the parties. Therefore, the secret agreement and actions of Tabitha and Freddie are irrelevant to overcoming the statutory bar.
Analysis:
This decision solidifies the legal principle that marital legitimacy and the stability of the family unit can outweigh biological parentage under the law. It reinforces that statutory time limits for challenging paternity are not mere procedural hurdles but reflect a substantive public policy to protect the established parent-child relationship. The ruling makes it clear that parties cannot rely on private agreements or conduct to circumvent these strict deadlines. This strengthens the finality of parentage for children born within a marriage and limits the ability to disrupt established family relationships years after a child's birth.
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