Utah Supreme Court
Does Utah law allow biological fathers to challenge paternity when a child is born during marriage? Olguin v. Anderton Explained
Summary
Jimmy Olguin conceived a child with Marie Anderton while she was married to Christopher Anderton, who was presumed to be the father under Utah law. When Olguin filed a paternity petition, Mother moved to dismiss arguing he lacked standing under the UUPA. The district court denied the motion on constitutional grounds, and the case was certified to the Utah Supreme Court.
Analysis
In Olguin v. Anderton, the Utah Supreme Court addressed a critical question about paternity standing under the Utah Uniform Parentage Act (UUPA): Can an alleged biological father challenge paternity when a child was born during the mother’s marriage to another man?
Background and Facts
Jimmy Olguin conceived a child with Marie Anderton during a separation from her husband Christopher Anderton. When the child was born in 2012, Christopher was listed as the father on the birth certificate and enjoyed presumed paternity under Utah law. Genetic testing later established a 99.99 percent probability that Olguin was the biological father. After Marie terminated Olguin’s contact with the child in 2016, he filed a paternity petition. Marie moved to dismiss, arguing that subsection 78B-15-607(1) of the UUPA denied standing to alleged fathers when children are born during marriage.
Key Legal Issues
The central issue was whether the UUPA grants standing to alleged biological fathers to challenge presumed paternity when a child is born during the mother’s marriage. The district court had ruled that denying such standing would violate procedural due process rights under the Fourteenth Amendment.
Court’s Analysis and Holding
Rather than addressing the constitutional issues, the Utah Supreme Court resolved the case on statutory interpretation grounds. The court held that the UUPA does grant standing to alleged fathers under subsection 602(3), and that subsection 607(1) does not limit this standing when children are conceived or born during marriage with a presumed father. This interpretation rendered the constitutional claims moot.
Practice Implications
This decision provides clarity for practitioners handling paternity cases involving married couples. Alleged biological fathers now have clear statutory standing to challenge presumed paternity, eliminating the need to rely on constitutional arguments. The court affirmed on alternative grounds, demonstrating how appellate courts may avoid constitutional questions when statutory interpretation provides adequate resolution.
Case Details
Case Name
Olguin v. Anderton
Citation
2019 UT 73
Court
Utah Supreme Court
Case Number
No. 20180098
Date Decided
December 19, 2019
Outcome
Affirmed
Holding
The Utah Uniform Parentage Act grants standing to alleged fathers to adjudicate paternity even when a child was conceived or born during a marriage with a presumed father.
Standard of Review
Correctness for questions of law regarding interpretation and constitutionality of a statute
Practice Tip
When challenging paternity under the UUPA, practitioners should cite both subsection 602(3) for general standing and argue that subsection 607(1) does not limit this standing when children are born during marriage.
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