Supreme Court of Missouri / Feb 24, 2026
In re the matter of: A.L.P. and S.H.P., minors; Alicia Smith, Respondent, vs. Lora Martinez, Appellant.
Citation: Hanson v. Carroll, 527 S.W.3d 849
The Missouri Supreme Court reversed the circuit court's grant of third-party visitation to Smith under section 452.375.5(5)(a), holding that this statute does not create an independent cause of action for third-party visitation when custody is not at issue. The court determined that Smith lacked standing to seek visitation rights after Martinez was granted full parental rights through adoption.