Louisiana courts have remained conveniently silent regarding de facto or psychological parentage in their legislation and case law. In Gill v Bennet, a grandmother appealed a lower court ruling claiming she was the "psychological parent" of her grandchild due to a guardianship order from an Indiana court. The court noted that there are no cases or laws expressly addressing de facto parents in Louisiana. There have been custody and visitation cases involving “psychological parenting” claims by grandparents, which resulted in the development of La. Civ. Code Art. 136 and La.RS 1344. The court considered his appeal as a grandparent or third party seeking custody of a natural parent. The court upheld the trial court's decision granting joint custody to the child's parents, designating the father as the domiciliary parent, refusing to recognize the grandmother as the de facto parent, but granting him visitation rights under of Civil law. Code Art. 136 because “extraordinary circumstances” existed.AdoptionAdoption options in Louisiana for same-sex couples are extremely limited. Louisiana code provides: “A single person, eighteen years of age or older, or a married couple may apply for the adoption of a child through an agency. » This means that gay and lesbian couples can adopt individually. The code explicitly states that for a couple to adopt, they must be married. Gay and lesbian couples cannot legally marry in Louisiana because it is strongly against public policy. Therefore, they cannot legally jointly adopt a child. Second-parent adoption is an important tool used by same-sex couples to protect their parental rights in states where same-sex marriage is not recognized. Although gay and lesbian parents...... middle of document ......y and de facto parents' visitation rights and support obligations, lesbian, gay, bisexual, and transgender family law § 7:14, December 2014. 2013. ALI Principles § 2.03 (b) (2000). Miller, citing Rule 1401(a)(8) of the Juvenile Court Rules of the California Court Rules. In re Guardianship of ZCW, 84 Cal.Rptr.2d 48, See In re Guardianship of ZCW, 84 Cal.Rptr.2d 48 (Ct. App. 1999) (having a lesbian parent does not entitle you to custody of a child conceived during a homosexual relationship); Curiale v. Reagan, 272 Cal. Rptr. 520 (Ct. App. 1990) (holding that a non-parent lacked standing to seek custody of a child's natural parent.) William Reppy, Jr. and Cynthia SamuelId.Id.Id.Palazzo v. MireLeitsingerAlan Duke. Hawaii will become the 16th state to legalize same-sex marriage. http://www.cnn.com/2013/11/12/us/hawaii-same-sex-marriage/