he ex-husband brought an action to deny paternity. "After RRK, the presumption that a child conceived during a lawful marriage is the husband's may only apply to those situations in which the mother remarries prior to the institution of paternity proceedings." Since Sally remarried before Harry questioned whether he is the father, RRK can be distinguished from the present case.
Further inroads on the presumption were, however, made in cases holding that a natural father who was not the mother's husband might have custody or visitation rights if he could show that he had a "substantial parent-child relationship." C.C. v. A.B., 406 Mass. 679, 550 N.E.2d 365 (1990). In that case, the Supreme Judicial Court said that "there is no longer any need for a presumption of legitimacy" and that Ch. 209C "has effectively eliminated the presumption of legitimacy."
Massachusetts courts determine the rights of putative fathers, fathers other than the husband at the time the child is born, whether they claim they are or not the father of t
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