This Note discusses the 2018 Supreme Court of Missouri decision of Bowers v. Bowers, which awarded full custody of a child to her stepfather. The facts in Bowers are discussed in Part II. Part III analyzes the Missouri Uniform Parentage Act and the approaches the Supreme Court of Missouri and Missouri appellate courts have taken when a child’s non-biological parent seeks full custody. Part IV explains the Supreme Court of Missouri’s rationale in granting full custody to the stepfather through a motion for third party custody and the dissent’s disagreement. Finally, Part V discusses why the Bowers court should not have awarded the stepparent custody as a third party and instead should have considered the stepparent to be the “natural father.”

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