March 26, 2026
Court of Appeal, Fourth Appellate District, Division One
The Rule of Steven N. v. Priscilla C. is that a voluntary declaration of parentage (VDOP) is void as a matter of law when, at the time of signing, a third party is already a presumed parent under Family Code section 7611, subdivision (b), even if that presumed parent status arises from an invalid marriage solemnized in apparent compliance with law.