id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjgl-2560	Goldberg, Suzanne B.	Family Law Cases as Law Reform Litigation: Unrecognized Parents and the Story of Alison D. v. Virginia M.	2008	36	.pdf	application/pdf	16099	709	57	The appellate court's brief opinion also summarily rejected Alison's equitable estoppel theory and the constitutional arguments advanced by the ACLU.8° In a rhetorical move that has now become standard for courts denying familial status to lesbians and gay men,8' the Appellate Division stressed that the decision intended no disrespect to Alison personally by stating: We do not, by virtue of our determination on this issue, minimize, in any way, the close and loving relationship that the petitioner has 76 Alison D., 552 N.Y.S.2d at 322-24. ld. [Vol. 17:3 Family Law Cases as Law Reform Litigation Vermont Supreme Court did the same, citing Alison D. for the proposition that a non-biological parent was not a parent for purposes of visitation rights.11 7 Notably, several courts also relied on Alison D. to deny standing to adults who had parented children while in heterosexual relationships, confirming the concerns of Alison's lawyers that the decision would cast a broad, harmful shadow.11 8 The legal fallout in the years immediately following Alison D. did not entirely track the New York Court of Appeals' approach, however.	cache/cjgl-2560.pdf	txt/cjgl-2560.txt
