Father Had Physical Custody Of Child
Child was in the “physical custody” of father at time non-parents seeking adoption filed petition to intervene, thus denying non-parents standing to seek child’s custody, where father acted to protect his interest and establish his relationship with child, father had not been declared father of child when child was placed with persons seeking adoption, father brought suit for declaration of paternity before child was born, and non-parents who took possession of child had no contact with father to determine his desires. Brumfield v. Yard.