J-S28001-25
2025 PA Super 233
DANIELLE HALE : IN THE SUPERIOR COURT OF : PENNSYLVANIA v. : : KYRA HALE : : v. : : BREANNA MILLER : No. 651 MDA 2025 : Appellant : :
Appeal from the Order Entered April 16, 2025 In the Court of Common Pleas of Luzerne County Civil Division at No(s): 2021-03126
KYRA HALE : IN THE SUPERIOR COURT OF : PENNSYLVANIA v. : : DANIELLE HALE : : v. : : BREANNA MILLER : No. 729 MDA 2025 : Appellant : :
Appeal from the Order Entered April 16, 2025 In the Court of Common Pleas of Luzerne County Civil Division at No(s): 2021-02780
BEFORE: BOWES, J., OLSON, J., and KING, J.
OPINION BY BOWES, J.: FILED: OCTOBER 15, 2025
Breanna Miller (“Appellant”) appeals the April 16, 2025, order that
denied her petition to intervene in custody proceedings pertaining to L.M., a J-S28001-25
female child born in 2011, and G.H., a male child born in 2018 (collectively,
“the Children”). We reverse and remand with instructions.
We glean the relevant factual and procedural history of this matter from
the certified record. Although both custody matters are listed above, the
instant appeal solely pertains to Appellant’s request to intervene and seek
partial physical and shared legal custody of G.H. The trial court aptly
summarized the relevant contours of the beginning of this litigation as follows:
This case has a long and complex history. The parties to this case are Kyra Hale [(“Kyra”)] and Danielle Hale [(“Danielle”)]. Kyra is the biological mother of the Children, and Danielle is the former spouse of Kyra and second parent to the Children. Upon separation of the parties in 2021, Kyra remained in Luzerne County, Pennsylvania, with L.M., and Danielle relocated to New Jersey with G.H. There has been a significant amount of litigation between the parties regarding the custody arrangement of the Children.
Trial Court Opinion, 5/30/25, at 1 (cleaned up). The court also cogently
recounted the relevant aspects of the custody litigation that predated the
instant controversy:
The most recent [c]ustody [o]rders dated February 7, 2023[,] and June 4, 2024[,] provide that [Kyra and Danielle] share legal custody of [the Children], with Kyra having primary physical custody of L.M. and Danielle having primary physical custody of G.H. Kyra has partial physical custody of G.H. on alternating weekends, and Danielle has partial physical custody of L.M. on alternating weekends, with the parties’ weekends each coinciding such that [the Children] are together each weekend, regardless of which parent’s home they are at.
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Id. at 2. We note that these custody awards are also generally reflective of
the awards predating February 2023. See N.T., 2/27/25, at 83.1
Danielle began dating Appellant in August 2021, while she and G.H. still
resided in New Jersey. Id. at 6. Between August 2021 and January 2022,
Appellant began assisting Danielle in caring for G.H. by watching him on
several occasions and assisting in his potty-training regimen. Id. at 83-84,
254. In February 2022, Appellant, Danielle, and G.H. collectively relocated to
Chester County, Pennsylvania, and began living together as a family unit. Id.
at 7-8, 86. The certified record indicates that while they cohabited for
approximately three years, Appellant played a significant role in co-parenting
G.H. and providing for his day-to-day care.
Danielle and Appellant ended their relationship in September 2024 after
unsuccessfully attempting “co-parenting” counseling. Id. at 8, 136-37.
Consequently, Appellant relocated to a different unit of the same apartment
complex as G.H. and Danielle. Id. at 8. On November 29, 2024, Appellant
sought permission to intervene in the custody proceedings pursuant to 23
Pa.C.S. § 5324. Specifically, Appellant alleged that she had standing with
respect to G.H. upon the basis of in loco parentis. See Petition for Permission
to Intervene, 11/29/24, at ¶¶ 4-8. She claimed that she performed parental
____________________________________________
1 The notes of testimony in this case are combined and encompass the full testimony from both hearings on February 27 and March 20, 2025, respectively. To avoid unnecessary confusion, we will refer only to the first hearing date in our citations to the relevant transcript passages in this writing.
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duties with parental consent from 2021 until the time her relationship with
Danielle ended in September 2024. Id. at ¶ 5(a)-(e). In addition, she
attached to the petition a motion to modify custody that expressed her intent
to seek shared legal custody and partial physical custody of G.H. Id. at Exhibit
B.
On December 10, 2024, Danielle sought a protection from abuse (“PFA”)
order in an attempt to restrict Appellant’s contact with G.H. See N.T.,
2/27/25, at 168. Ultimately, the trial court denied the PFA petition, which was
described as a “retaliatory” filing that lacked merit. Id. Despite these events,
Danielle continued to permit G.H. to visit Appellant, with the most recent
interaction occurring in approximately February 2025. Id. at 168-69.
Communications in the certified record also reveal that Danielle offered to
enter into an “unofficial custody arrangement” that would have permitted
Appellant to have contact with G.H. in exchange for a monthly stipend of
between $1,000 and $2,000. Id. at 171-72. Appellant declined to enter into
such an agreement. Id. at 170-71.
The trial court held hearings on February 27 and March 20, 2025,
wherein the parties testified. Additionally, G.H.’s guardian ad litem, Jessica
Pleskach, Esquire, also briefly attested to G.H.’s feelings regarding Appellant.
On April 16, 2025, the trial court filed an order and opinion that denied
Appellant’s request to intervene. Of note, both Appellant’s petition and the
court’s order listed both of the Children’s custody docket numbers.
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On May 13, 2025, Appellant timely filed a single notice of appeal listing
both docket numbers.2 Appellant did not contemporaneously file a concise
statement of errors complained of on appeal pursuant to Pa.R.A.P.
1925(a)(2)(i) and (b). However, the trial court directed her to file a concise
statement, and she timely complied.3 The trial court submitted a responsive
Rule 1925(a)(2)(ii) opinion, which reiterated the reasoning in its original
order.
Appellant raises the following issues for our consideration:
1. Did the trial court commit an error of law and/or an abuse of discretion in determining and identifying [Appellant] as a caregiver and performed [sic] tasks as a caregiver and not assuming a parental role and performing parental duties?
2. Did the trial court commit an error of law and/or an abuse of discretion in determining that Kyra did not provide permission for [Appellant] to perform parental duties and that both Kyra and [Danielle] unequivocally objected to [Appellant] acting as a parent and performing parental duties? ____________________________________________
2 As such, this Court entered an order noting that Appellant’s notice did not
comply with Commonwealth v. Walker, 185 A.3d 969, 977 (Pa. 2018) (requiring appellants to file separate notices of appeal when a single order resolves issues arising on more than one lower court docket). We directed her to file amended notices of appeal pursuant to Pa.R.A.P. 902(b)(1) within ten days. See Commonwealth v. Young, 280 A.3d 1049, 1057 (Pa.Super. 2022) (holding defects pursuant to Walker are susceptible to correction under Rule 902(b)(1) unless “good cause” is shown otherwise). Appellant timely complied, and we thereafter consolidated these cases sua sponte. See Pa.R.A.P. 513.
3 Since no party has alleged prejudice as a result of these events, we decline
to find waiver. See In re K.T.E.L., 983 A.2d 745, 747 n.1 (Pa.Super. 2009) (holding an appellant’s failure to simultaneously filed a Rule 1925 statement in a Children’s Fast Track case did not result in waiver where the appellant later filed a statement and there were no allegations of prejudice).
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3. Did the trial court commit an error of law and/or an abuse of discretion in determining that the relinquishment of parental rights by [Danielle] and Kyra was necessary for [Appellant] to establish in loco parentis status?
4. Did the trial court commit an error of law and/or an abuse of discretion in determining that evidence of strong bond with the minor child after separation is necessary for a finding of in loco parentis status?
Appellant’s brief at 9 (cleaned up).
These issues collectively pertain to in loco parentis standing in custody
proceedings. Our Supreme Court has delineated our standard and scope of
our review in such cases thusly:
Issues of standing generally raise pure questions of law for which we employ a de novo review of a trial court’s decision. As well, a challenge to asserted in loco parentis status in a particular context typically involves a fact-intensive inquiry, and may implicate mixed questions of law and fact. Where factual findings and credibility determinations are at issue, we will accept them insofar as they are supported by the record. In matters arising under . . . appeals of child custody . . . decisions, our plenary scope of review is of the broadest type; that is, an appellate court is not bound by the trial court’s inferences drawn from its findings of fact, and is compelled to perform a comprehensive review of the record for assurance the findings and credibility determinations are competently supported.
Interest of K.N.L., 284 A.3d 121, 133 (Pa. 2022) (cleaned up).
At a basic level, “[s]tanding relates to the capacity of an individual to
pursue a particular legal action, and requires the petitioning litigant be
adversely affected, or aggrieved, in some way.” K.N.L., 284 A.3d at 136.
Traditionally, this requirement is met “when an individual demonstrates [that
she] has a substantial interest in the subject matter of the litigation” that is
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“direct and immediate, rather than remote, and which distinguishes [her]
interest from the common interest of other citizens.” Id. (cleaned up). With
respect to the instant case, Pennsylvania statute confers standing to seek
custody upon individuals who stand in loco parentis to a child. See A.C. v.
E.K., 331 A.3d 939, 945-46 (Pa.Super. 2025); see also 23 Pa.C.S. § 5324(2).
The term “in loco parentis” literally means “in place of a parent.” A.C.,
331 A.3d at 946 (cleaned up). Specifically, it “refers to a person who puts
oneself in the situation of a lawful parent by assuming the obligations incident
to the parental relationship without going through the formality of a legal
adoption.” K.N.L., 284 A.3d at 144. The High Court has further explained
that “[t]he foundational elements of in loco parentis status, upon which all
other considerations may rise or fall, include the assumption of a parental
role, and the discharge of parental duties.” Id. (citing C.G. v. J.H., 193 A.3d
891, 907-08, 910 (Pa. 2018)) (emphasis added). The assumption of a
parental role, however, must originate with a legal parent’s assent, whether
through encouragement or acquiescence. Id. The High Court has also held
that “the relevant time frame to determine whether a party stands in loco
parentis is when the party developed the relationship with the child with the
acquiescence or encouragement of the natural parent.” Id. at 145.
In order to acquire standing in this fashion, a litigant must prove that a
parent-like relationship has been forged through the parties’ conduct to
establish in loco parentis standing and seek custody. See A.C., 331 A.3d at
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946. While this test is “stringent” to “prevent intrusion into fundamental
parental rights” by “those who are merely strangers,” our Supreme Court has
cautioned it must not be interpreted “so rigidly or absolutely as to deny one
acting in loco parentis an opportunity to be heard[.]” K.N.L., 284 A.3d at
139. We also remain especially mindful that a third-party litigant, like
Appellant, “who is not biologically related to the child but [who] has
established a parent-like relationship with the child [and] seeks not to
supplant the natural parent, but only to maintain [her] relationship with the
child through reasonable visitation or partial custody,” has an easier burden
to meet.” J.A.L. v. E.P.H., 682 A.2d 1314, 1320 (Pa.Super. 1996).
With these legal principles in mind, we turn to the merits of Appellant’s
arguments. The crux of her claims is that the trial court erred in concluding
that she did not stand in loco parentis to G.H. See Appellant’s brief at 14
(“[T]he trial court ignored the detailed testimony and substantial evidence
presented by [Appellant] with regard to her assumption of a parental role and
discharge of parental duties and instead determined that [Appellant] was
simply a caregiver.”). Appellant maintains that the evidence of record
“unequivocally demonstrates that she meets the threshold for a finding of in
loco parentis.” Id. at 15. We agree.
In its opinion, the trial court acknowledged that Appellant performed
numerous “caregiver” tasks during the three years that she lived with G.H.
and Danielle. See Trial Court Opinion, 5/30/25, at 11 (“The testimony
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established that [Appellant] performed many caregiving tasks for the minor
child[.] . . . Importantly, for nearly all this time, [Appellant] and Danielle lived
together as romantic partners.”). The court, however, concluded that
Appellant could not establish in loco parentis status because neither Danielle
nor Kyra gave their “consent” for her to take on the various responsibilities
regarding G.H. Id. The trial court also opined that Appellant could not
demonstrate entitlement to in loco parentis status since neither Danielle nor
Kyra had “relinquished” their “parental rights” between 2021 and 2024. Id.
at 12. Finally, the court determined that Appellant’s request to intervene
failed since she did not show that she had a close psychological bond with
G.H. Id. at 13.
Respectfully, our review indicates the trial court’s analysis is legally
flawed. Contrary to the court’s holding, the relationship between Danielle and
Appellant bears all the traditional hallmarks of a caregiver relationship that
yields in loco parentis status. As our Supreme Court has explained, “[o]ne of
the most obvious demonstrations of an in loco parentis relationship is where
the natural parent and third party lived together as a ‘family unit’ while co-
parenting the child.” K.N.L., 284 A.3d at 145 (citing T.B. v. L.R.M., 786 A.2d
913, 919 (Pa. 2001)). Indeed, this Court has plainly observed that “[w]hen
the party asserting in loco parentis status lives with the child and a natural
parent as a family unit, our courts have held that the party has standing.”
D.G. v. D.B., 91 A.3d 706, 709 (Pa.Super. 2014) (citation omitted). Under
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the facts of this case, it is clear that Appellant’s relationship with G.H. during
the course of the three years she was involved with Danielle fell squarely
within this well-defined rubric.
In addition to living with and assisting Danielle with G.H.’s everyday
care, the certified record reflects that her involvement was much more akin
to a co-parent than merely a babysitter or occasional caregiver. Particularly,
Appellant was included in decision-making concerning the selection of G.H.’s
medical providers, as well as helping to schedule and take G.H. to his various
medical, dental, and therapy appointments. See N.T., 2/27/25, at 91-92,
116-18, 124-27, 132-3, 267-68. Appellant was also entrusted with registering
G.H. for school and sports activities. Id. at 94-95, 101, 142, 151-54. She
had independent access to the school’s parent portal and was listed as a
“secondary parent” on some of G.H.’s educational paperwork. Id. at 94-95,
101, 142, 269. Appellant was included in communications regarding G.H.’s
education and regularly attended parent-teacher conferences and G.H.’s
school functions, including numerous occasions when she appeared as the sole
parental representative from her household. Id. at 94-95, 104-06, 111-16,
139. Additionally, Appellant served as G.H.’s “homeroom mom” when he
entered first grade and she volunteered weekly with his school’s parent-
teacher organization (“PTO”). Id. at 129-31, 270. Appellant further took on
various financial obligations with respect to G.H., including paying for clothing,
sports programs, and groceries. Id. at 151-54, 270-73.
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The above-described testimonies of Danielle and Appellant collectively
reveal that Appellant was closely involved in the day-to-day care of G.H. and
also played an important role in choosing his medical providers and acting in
a parental role concerning his education. See N.T., 2/27/25, at 91-92, 116-
18, 124-27, 132-3, 267-68. Indeed, Danielle testified that she discussed
parental decisions regarding G.H. equally with both Appellant and Kyra during
the relevant period of time. Id. at 10 (“[M]ost of the decisions I would talk
to Kyra about and [Appellant] about regardless of who was first or not.”).
While Danielle indicated she was largely responsible for “hands-on parenting,”
she also conceded that Appellant was “actively helping take care” of G.H.,
particularly with respect to “administrative” tasks involving his medical and
educational needs. Id. at 18, 24. Tellingly, Kyra’s testimony similarly
indicated that Appellant largely overtook Kyra’s parental role as to G.H. during
the course of her long-term romantic relationship with Danielle. She
explained, “[b]ecause all of this, I was left out for the last three years. I’ve
been blatantly left out of my child’s life[.]” Id. at 282.
In all, the certified record reveals that Appellant accepted many
obligations that fall squarely within the realm of parental responsibility and
stature. See K.N.L., 284 A.3d at 145; D.G., 91 A.3d at 709. As a threshold
matter, these facts augur strongly in favor of awarding Appellant in loco
parentis status. See T.B., 786 A.2d at 709 (holding that a woman who lived
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with her girlfriend and “shared day-to-day child rearing responsibilities” for
three years prior to their break-up was entitled to in loco parentis status).
We recognize, however, that the trial court’s denial of intervention was
largely predicated upon its conclusion that Appellant lacked consent from
either Danielle or Kyra to take on a parental role. See Trial Court Opinion,
5/30/25, at 11-12. Assuming, arguendo, that Appellant never received
explicit permission from either of G.H.’s legal parents, the certified record
indicates that both Danielle and Kyra permitted Appellant to take on a parental
role through their acquiescence of her efforts on G.H.’s behalf. This tacit
ratification is consistent with consent to in loco parentis status. See M.J.S.
v. B.B., 172 A.3d 651, 657 (Pa.Super. 2017).
Specifically, Danielle testified she made no attempt to prevent Appellant
from undertaking the above-described parental responsibilities:
[DANIELLE’S ATTORNEY]: Why did you – why did you let [Appellant] do the things that she says she has done with [G.H.]?
[DANIELLE]: Some of the things it was more of, like, I didn’t want the arguments in the house. Like, she would get very angry if I told her no, she couldn’t do something. Some of it, it just wasn’t worth the fight. Like, she would like oh, I sent an e-mail to the teacher about this; and, while I didn’t give her permission to send it, it wasn’t always worth the argument . . . .
It wasn’t worth it to me to sit here and fight with her about it.
See N.T., 2/27/25, at 251 (emphasis added).
Kyra similarly testified that she permitted Appellant to take on a parental
role without objection based upon her conclusion that Appellant was an
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“irrelevant” individual in her eyes. Id. at 285 (“I put up with what she did,
because I had no control over it because she was in the household.”). Kyra
further confirmed that she never reached out to Appellant to object because
she chose to communicate solely with Danielle. Id. at 286. Indeed, Kyra
explained that she relied upon Danielle to manage the relationship between
Appellant and G.H. Id. at 283-86. As detailed above, Danielle permitted
Appellant to take on a parental role.
Overall, we find this case to be analogous to M.J.S. There, this Court
concluded that a biological parent who “did not attempt to intercede” in
another party’s “assumption of parental duties” had “acquiesced” to the
development of an in loco parentis relationship through “implicit approval” by
“failing to act.” M.J.S., 172 A.3d at 657. More particularly, we held that a
legal parent who permitted a grandparent to perform “at least a shared role
of carrying out the day-to-day care” for a child “acted in a manner consistent”
with having given consent to the establishment of an in loco parentis
relationship. Id.; see also Tarr v. Young, 287 A.3d 882, 2022 WL 12213672
at *6 (Pa.Super. 2022) (non-precedential decision) (holding that a natural
parent’s failure to act while a non-related, third-party petitioner performed
parental duties resulted in the creation of in loco parentis standing).
The above-quoted testimony from Danielle and Kyra leaves no question
that they similarly acquiesced to Appellant’s assumption of a parental role
through passive acceptance for several years. Even absent express consent,
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G.H.’s legal parents freely allowed Appellant to closely share parental
responsibilities and take on an analogous stature. Thus, we hold the trial
court legally erred in concluding otherwise.4
Similarly, we reject the trial court’s suggestion that Kyra and Danielle
were required to fully “relinquish” their parental rights to G.H. in order for
Appellant to acquire in loco parentis status. See Trial Court Opinion, 5/30/25,
at 12. In M.J.S., this Court refuted the notion that a party seeking to establish
in loco parentis standing was required to assume the role of a “sole parental
figure” in order to attain such status. See M.J.S., 172 A.3d at 656-7. Our
caselaw provides that sharing in the day-to-day responsibilities of raising a
child in the role of a co-parent is sufficient to establish in loco parentis
standing. Id. (citing T.B., 786 A.2d at 709). As detailed above, there is no
dispute Appellant undertook numerous shared parental obligations on G.H.’s
behalf over a three-year period, which included independent input regarding
4 The trial court’s denial of Appellant’s intervention request on consent grounds was principally predicated upon the non-precedential holding Thompson v. Davis, 258 A.3d 533, 2021 WL 2472885 (Pa.Super. 2021) (non-precedential decision). See Trial Court Opinion, 5/30/25, at 11-12. In Thompson, this Court concluded that a third-party petitioner failed to establish in loco parentis status due to the lack of “express consent” from one of the natural parents. Davis, 2021 WL 2472885 at *9. Critically, however, this holding simultaneously acknowledged that M.J.S. presented a contrary interpretation of Pennsylvania law. Id. at *9 (citing M.J.S., 172 A.3d at 657). For reasons that are unclear, the panel in Thompson declined to apply M.J.S. Based upon the analysis above, however, the instant case parallels the precedential holding of M.J.S. Under the specific facts of this case, we find Thompson to be unpersuasive.
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his medical providers, education, and general welfare. See N.T., 2/27/25, at
91-95, 101, 111-18, 124-27, 132-3, 139, 142, 151-54, 267-73.
Finally, we address the aspect of the trial court’s reasoning that
concluded Appellant was required to show she had a close psychological bond
with G.H. in order to establish in loco parentis standing. See Trial Court
Opinion, 5/30/25, at 13 (“[T]he [c]ourt has no testimony or evidence to
suggest that G.H. had a strong psychological bond with Appellant, that G.H.
viewed Appellant as a parent, or that he continues to have a strong bond and
view Appellant as a parent.”). Once more, a review of our governing
precedent indicates that the trial court misapplied the law.
We acknowledge, of course, that both this Court and our Supreme Court
have previously noted that in loco parentis status should generally be awarded
“where the child has established strong psychological bonds with a person
who, although not a biological parent, has lived with the child and provided
care, nurture, and affection, assuming in the child’s eye a stature like that of
a parent.” J.A.L, 682 A.2d at 1320; see also T.B., 782 A.2d at 917 (citing
J.A.L., 682 A.3d at 1319-20). The trial court explicitly relied upon this
language in rendering its holding. See Trial Court Opinion, 5/30/25, at 5, 11.
Respectfully, though, we believe that the trial court failed to view these cases
in the proper legal context.
Our Supreme Court has subsequently clarified that affirmative proof of
a strong psychological bond between a child and a third-party petitioner is not
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a required element to establish in loco parentis standing to seek custody. See
C.G., 193 A.3d at 909-10 (concluding that the arguable bond between a third-
party petitioner and a child is not a “decisive factor” concerning in loco parentis
standing); see also K.N.L., 284 A.3d at 145-46 (indicating that the extent of
a bond between a third party and a child is a “secondary” consideration in
standing inquiries). Indeed, our High Court has reasoned that requiring a
strict bonding analysis in this context would be a “loose application” of
Pennsylvania law that would “undermine well-established principles of in loco
parentis analyses.” C.G., 193 A.3d at 909-10. Specifically, our Supreme
Court has explained that
the import of the J.A.L. decision is not to introduce an examination of bonding into a standing inquiry, but rather to recognize a bond exists with a nonbiological caregiver just as with the natural parent where the caregiving role is assumed during a child’s . . . early childhood; that is, where one has lived with the child and provided care, nurture, and affection, assuming in the child’s eye a stature like that of a parent . . . , the primacy of the resulting bond warrants a prima facie right to in loco parentis status to be heard regarding the substance of the child’s best interests.
K.N.L., 284 A.3d at 146 (emphasis added). While it is “a concern to the courts
whether a child has developed strong psychological bonds” with a petitioning
party, such an inquiry with respect to standing is only relevant “insofar as it
sheds light on whether the person seeking standing was ever viewed as a
parental figure.” Id. (citation omitted).
Based upon the foregoing, we cannot countenance the trial court’s
reasoning on this particular point. By requiring strict and literal proof of a
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close psychological bond between G.H. and Appellant, the trial court
misapplied J.A.L. and failed to recognize the limiting interpretations issued by
our Supreme Court in C.G. and K.N.L. As discussed at length above,
Appellant assumed a “caregiving” role toward G.H. while she lived with him
between the ages of three and six years old, which our caselaw has reasoned
elevates Appellant, in the child’s eyes, to “a stature like that of a parent.”
K.N.L., 284 A.3d at 133; see also J.A.L., 682 A.2d at 1321-22 (holding
petitioner established the existence of a psychological bond for standing
purposes by proving she had “the opportunity for bonding” with a child by
providing care of a parental nature during a significant portion of their early
childhood).
In sum, we conclude that the trial court erred in denying Appellant’s
request to intervene. By cohabiting and assuming parental responsibilities for
three years of G.H.’s early childhood, Appellant satisfied the basic parameters
of in loco parentis. See T.B., 786 A.2d at 709. Furthermore, we hold that
the inaction of Danielle and Kyra resulted in their acquiescence to Appellant’s
assumption of a parental role. See M.J.S., 172 A.3d at 656-57. Finally, the
trial court erred in requiring strict and literal proof of a strong psychological
bond between G.H. and Appellant as a prerequisite to in loco parentis
standing. See K.N.L., 284 A.3d at 146; C.G., 193 A.3d at 910. Furthermore,
the length and quality of Appellant’s involvement in co-parenting G.H.
sufficiently established the opportunity for Appellant to assume a stature like
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that of a parent from G.H.’s perspective. See K.N.L., 284 A.3d at 133; J.A.L.,
682 A.2d at 1319-22.
Accordingly, we hereby reverse the order denying Appellant’s request
to intervene and remand for further proceedings consistent with this holding.5
Order reversed. Case remanded. Jurisdiction relinquished.
Judgment Entered.
Benjamin D. Kohler, Esq. Prothonotary
Date: 10/15/2025
5 We also emphasize that “[a] determination of standing simply implies that the party has a substantial interest in the subject matter of the litigation and that the interest is direct, immediate and not a remote consequence.” T.B. v. L.R.M., 786 A.2d 913, 920 (Pa. 2001). Accordingly, our holding in this case “does not speak to [Appellant’s] chance of success on the merits, but merely affords her the opportunity to fully litigate the issue.” Id.
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