When people imagine a custody case, they picture two parents fighting over their child. But for many North Carolina families, that picture no longer reflects reality. Children are often raised by unmarried partners, extended family members, or caregivers who step into a parental role long before the legal system ever becomes involved. In those situations, the line between “parent” and “non-parent” becomes blurry.
A recent decision from the North Carolina Court of Appeals, Bullins v. Riddle (2025), addresses exactly this problem. It is an important case — not only because of its outcome, but because of what it says about modern parenthood, children’s stability, and when a non-parent can lawfully step into the shoes of a parent.
At its core, Bullins v. Riddle reminds us that the law does not see parenthood only through the lens of biology. Instead, it looks closely at the actual lived experience of the child. And when a biological parent has voluntarily allowed someone else to function as a parent in every meaningful way, the law may ultimately protect that relationship — even over the biological parent’s objection.
A Family That Looked Like a Family
The child in this case, referred to as K.B., was raised from birth by his mother and the mother’s partner, Haley Riddle. They lived together as a family from the time K.B. was born. Riddle helped care for him every day, took him to appointments, participated in the routines of parenting, and became, in practice, a second parent.
When the adults’ romantic relationship ended, the shared parenting continued. The mother moved out, but both parties agreed that K.B. benefited from having both of them in his life.
At that point, custody became a legal question. Riddle filed a motion to intervene in the original custody case, asking the court to recognize her as a person with standing — someone with the right to be heard on matters involving the child. The trial court reviewed the history of the relationship and ultimately agreed: Riddle was allowed into the case and was granted joint custody.
This was not the end of the matter. As the years went on, conflict resurfaced. Exchanges became tense, communication deteriorated, and concerns about the child’s emotional well-being grew. The trial court eventually awarded Riddle primary legal and physical custody, giving the mother visitation. That order went unchallenged at the time, and it later became the foundation for the appeal.
A Modern Legal Question: When Does a Non-Parent Become a Psychological Parent?
Legally speaking, North Carolina strongly protects a parent’s constitutional right to the care and custody of their child. Under normal circumstances, a non-parent cannot simply step in and demand parental rights — and courts cannot treat a non-parent as a parent unless something exceptional has occurred.
This case presented exactly that question: Had the mother acted in a way that was inconsistent with her constitutional parental rights by allowing Riddle to act and become a full parent?
The trial court found that she had. The key facts were unavoidable:
- Mother and Riddle lived together with the child from birth.
- Mother allowed Riddle to make decisions, provide daily care, and act as a parent.
- Their family functioned as a two-parent household.
- Even after the breakup, mother continued to rely on Riddle as a primary caregiver.
By doing so, the mother had voluntarily shared parental authority, which legally transformed the relationship. In the words of North Carolina precedent, the mother had acted “inconsistently” with her exclusive parental rights. That inconsistency does not punish the parent — it protects the child’s stability by recognizing the reality of their family life.
The Breakdown and the Trial Court’s Response
After the 2022 custody order, the relationship between the adults deteriorated further. Both parties accused each other of poor communication, undermining behavior, and difficulty with transitions. The child reportedly began experiencing emotional distress during exchanges. The mother violated the custody order by enrolling the child in daycare without consent and supervising him there during her entire shift.
In response, Riddle sought modification of custody and also asked the court to hold the mother in criminal contempt for violating prior orders. After hearings in early 2024, the trial court adjusted the custody arrangement, affirming Riddle’s primary custodial role and reducing the mother’s mid-week visitation. The court also found mother in contempt and imposed a suspended sentence.
Mother appealed.
What the Court of Appeals Held — And Why It Matters
The Court of Appeals took a balanced approach.
First, it confirmed that the trial court was correct to treat Riddle as a psychological parent with legal standing. This was the heart of the case. The mother had allowed Riddle to become a full, functioning parent for years, which meant that Riddle had a right to participate fully in the custody case and to be considered in any custody determinations. The appellate court affirmed this foundational principle and emphasized that it is rooted in the child’s best interests as well as constitutional law.
Second, the Court of Appeals found that the trial court had sufficient evidence to conclude that there was a substantial change in circumstances, which justified modifying the visitation schedule. The breakdown in communication, the daycare incident, the child’s difficulties with transitions, and the ongoing conflict all supported modification.
However, the appellate court also reminded trial courts that they must be precise and thorough in articulating the factual findings that support their decisions. Some parts of the order, particularly concerning the best-interest analysis and the criminal contempt ruling, lacked the required level of detail. Because of this, those portions of the case were vacated or remanded for further findings.
The message is clear: Non-parents may gain standing, but trial courts must still follow strict procedures when modifying custody or imposing contempt sanctions.
What This Means for Families and Lawyers
For families, Bullins v. Riddle reinforces a truth that most children already understand instinctively: a parent is someone who shows up every day and cares for you in all the meaningful ways that matter. Biology alone does not erase the bond a child forms with a long-term caregiver.
For parents, this decision serves as an important reminder. Inviting someone into a child’s life as a parenting figure — sharing decision-making, delegating responsibilities, and presenting that person as a co-parent to the world — may, over time, give that person legal rights. North Carolina courts honor the actual structure of family life, not just the labels attached to it.
For lawyers, the case is a strong reaffirmation of North Carolina’s “inconsistent-conduct” doctrine, which allows non-parents to overcome a parent’s constitutional prerogative when the parent has, by their own actions, elevated the non-parent into a parental role. The decision also highlights the need for precise findings, especially when modifying custody orders or handling criminal contempt.
A Case That Reflects Modern Families
Ultimately, Bullins v. Riddle is a case about what it means to be family in North Carolina today. It recognizes that many children grow up with more than one person acting in a parental role — and that their emotional stability depends on maintaining those bonds.
It also recognizes that parents have enormous freedom in shaping their children’s lives, but that with that freedom comes the responsibility to acknowledge the relationships they create. When a parent chooses to share the job of raising a child — day in and day out, for years — the law may protect that relationship, especially if it becomes central to the child’s sense of security.
In that way, Bullins v. Riddle is not simply a case about custody. It is a case about identity, responsibility, and the evolving landscape of parenthood.
If you or someone you know is navigating a complex custody situation — whether as a parent or a caregiver who has acted in a parental role — Adkins Law can help you understand your rights and chart a path forward that protects the child above all else.
Adkins Law – A Family Law firm located in Huntersville, North Carolina
At Adkins Law, we understand that every family’s story is unique — and that navigating custody, divorce, or separation in North Carolina can feel overwhelming. Our practice is dedicated to guiding parents and caregivers through difficult transitions with clarity, compassion, and strength. Whether you need help with custody disputes, third-party caregiver rights, mediation, or divorce in the Huntersville and Lake Norman area, we are here to protect what matters most: your family and your future. Reach out anytime to schedule a consultation and let us help you move forward with confidence.
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