In W.M. v. D.G., a non-dissolution matter, the plaintiff appealed from the orders directing her to return physical custody of a child to the defendant, the biological mother. The New Jersey Appellate Division reversed but did not remand because the child was due to turn eighteen in a few weeks. The Court held that the lower court erred by failing to undertake a complete examination of the plaintiff’s claim that she had become the child’s psychological parent.
