DeBoer ex rel. Darrow v. DeBoer

Background

A young child called Jessica has lived with the DeBoers, who believed they adopted her with the birth mother's consent. Later the biological father appeared, married the mother, and claimed parental rights. The Iowa Supreme Court ordered Jessica returned to her biological parents without deciding whether that move served her best interests. Jessica, through a next friend, and the DeBoers brought related suits in Michigan, challenging whether Michigan must accept the Iowa custody order without reexamining the child's welfare.

Reasoning

The core question is whether a Michigan court must give effect to an Iowa custody decree even when the Iowa court did not consider the child's best interests. The Michigan Supreme Court held that federal law requires such deference to the Iowa decree. The DeBoers relied on a New Jersey decision that allowed a later court to address the child's best interests, but Michigan rejected that approach. The request to pause (stay) Michigan’s decision while the Supreme Court considers review was presented to Justice Blackmun and referred to the full Court; the Court denied the stay application.

Real world impact

Because the stay was denied, the Michigan ruling that defers to the Iowa custody order remains in place for now. This outcome may lead to Jessica being returned to her biological parents despite the lack of a best‑interests finding by the Iowa court. The denial does not decide the full legal issues permanently; it only refuses to pause the lower‑court outcome while the Justices may later consider the case.

Dissents or concurrances

Justice Blackmun, joined by Justice O'Connor, dissented from the denial. He would have granted a stay because of the child's vulnerability and the clear disagreement between state high courts over whether a child's best interests must be considered.