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Appeals court considers whether grandparents had a "significant preexisting relationship" with child under Blix

Massachusetts Appeals Court · April 3, 2026
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Summary

Grandparents argued a five‑month period of co‑caregiving when the child was an infant plus years of subsequent visitation established a significant preexisting relationship that would make removal harmful; the mother————and her counsel said precedent sets a high bar and the trial judge correctly declined to order visitation.

Matthew Burack, representing the grandparents, told the panel that the record shows substantial contact — temporary primary caregiving when the child was an infant, then years of sustained visits — amounting to a "significant preexisting relationship" under Blix and related authority, and that the child's loss of that relationship after the death of the…

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