## Facts

- Gladys Miller married Jay Miller while her two children’s biological father, Ralph Febre, was incarcerated.
- During the marriage, the children lived with Gladys and Jay, and Jay treated them as his own, providing emotional and financial support and holding himself out as their father.
- After Febre’s release, Jay opposed and obstructed Febre’s efforts to have contact with the children, limiting the children’s relationship with their biological father.
- After the marriage deteriorated, Gladys sought child support from Jay for the two children, claiming Jay’s conduct and representations prevented him from denying a support obligation.
- The trial court ordered Jay to pay child support based on equitable estoppel, and the Appellate Division affirmed.

## Issues

1. Whether a stepparent who voluntarily assumed a parental role and represented himself as the children’s father may be required to pay child support after divorce under equitable estoppel.
2. What factual showing of reliance, detriment, and inequity is required to impose a support obligation on a non-biological parent despite the existence of a biological parent with a primary legal duty of support.

## Decision

- The New Jersey Supreme Court affirmed the support order against Jay Miller.
- The court held that equitable estoppel may impose a child-support obligation on a stepparent who affirmatively assumed full parental responsibilities and induced reasonable reliance by the children and custodial parent.
- The court found Jay’s long-term assumption of parenthood, combined with interference in the children’s relationship with their biological father, created detrimental reliance making it inequitable for Jay to withdraw support upon divorce.
- The court emphasized the ruling was fact-specific and did not create automatic support liability for all stepparents.

## Legal Principles

- Equitable estoppel may bar a person from denying a position previously asserted when others reasonably relied on that position to their detriment.
- In the child-support context, a non-biological parent may be estopped from denying a duty of support when the person:
  - affirmatively represented a parental status and undertook parental responsibilities over time, and
  - caused the child (and custodial parent) to rely on that status in a way that would make later withdrawal of support unfair.
- A biological parent’s primary legal duty of support does not categorically preclude imposing support on a stepparent when the stepparent’s conduct displaced the biological parent relationship and contributed to the child’s dependence.
- Liability is exceptional and turns on concrete evidence of assumption of parenthood, reliance, detriment, and resulting inequity.

## Conclusion

The court affirmed an equitable-estoppel-based child support order against a stepfather who held himself out as the children’s father, assumed parental responsibilities, and obstructed the biological father relationship, concluding that the children’s reliance and resulting detriment made it inequitable to allow the stepfather to disclaim support after divorce.


Miller v. Miller, 97 N.J. 154, 478 A.2d 351 (1984)