Illinois Supreme Court
Civil Court
Child Custody
Woman, a native of Slovakia, adopted a child Slovakia, while she was engaged to a man who was not Slovakian and who thus was unable, under Slovakian law, to adopt a Slovakian child. After couple broke off their engagement, child continued to live with her adoptive mother, and ex-finace filed petition for parentage, custody, and visitation. Doctrine of equitable adoption is limited to context of inheritance and does not apply to child custody. Mother was not equitably estopped from challenging her ex-fiance's standing to seek custody, visitation, and allocation of child support. Ex-fiance lacks statutory standing to bring custody petition. Illinois does not recognize functional parent theories. Adoptive mother alone has statutory parent-child relationship with child, as she is child's adoptive parent. As a fit custodial parent, adoptive mother has fundamental constitutional right to determine with whom child should associate. (GARMAN, THOMAS, KILBRIDE, KARMEIER, BURKE, and THEIS, concurring.)