Ashley Nicole Isabel Brito v. Jennifer Salas & Angel Giovanni Rivera v. Jennifer Salas

Summary

The Florida Supreme Court held that Florida Statutes section 742.14 does not automatically relinquish the paternal rights and obligations of a man who provides sperm for at-home artificial insemination. Interpreting the statute in context, the court concluded that its relinquishment provision applies to donations made as part of assisted reproductive technology involving the statutory concept of a commissioning couple. The court quashed the Second District Court of Appeal’s decision and left determination of any legal fatherhood rights to other applicable paternity law.

Holdings

1. Section 742.14 applies only when assisted reproductive technology is involved. Because the child was conceived through at-home artificial insemination, which did not involve the laboratory handling of human eggs or preembryos, section 742.14 did not automatically relinquish Rivera's paternal rights and obligations.
2. The court did not decide whether Rivera would ultimately establish legal fatherhood or obtain parental rights under traditional paternity statutes or other law; it held only that section 742.14 did not automatically eliminate his rights.
3. The Florida Supreme Court quashed the Second District's decision, disapproved A.A.B. v. B.O.C., and approved the outcome reached by the Fifth District in Enriquez v. Velazquez.

Questions Presented

1. Whether section 742.14, Florida Statutes, automatically relinquishes the paternal rights and obligations of a man whose sperm is used to conceive a child through at-home artificial insemination.
2. Whether section 742.14 applies only when assisted reproductive technology, as defined in section 742.13(1), is involved.
3. Whether the Second District's interpretation of section 742.14 should be disapproved and the Fifth District's contrary result in Enriquez approved.

Disposition

quashed