The Oklahoma Bar Journal January 2026

In a pre- Boatman relocation case, Scocos v. Scocos , 8 the mother was characterized as “always the Child’s primary caregiver, mak ing all the necessary decisions for the Child’s well-being.” In yet another relocation case, Le v. Nguyen , 9 the mother was charac terized as the primary custodial parent for the following reasons: The children spent the majority of their overnights with the mother, and the mother was responsible for the majority of the mundane, but essential, tasks of day-to-day parenting, including taking the children to the doctor, getting them ready for bed and helping them with school. The father’s role was described as significant.

other health care related needs. Their child has always referred to Ramey as “mom,” but did not begin to refer to Sutton as “mom” until the age of five or six. Even today, their child will sometimes refer to Sutton, the biological mom, as “Kimberly” and not as “mom.” Ramey has always been and continues to be listed as “other parent” at their son’s school. She was active in her child’s school, serving as home room mother, volunteer ing for school activities includ ing hosting class parties. Ramey has also built family traditions incorporating their child’s love of the outdoors.

physical custodian because the child’s primary residence was not designated in any court order and because the child resided equally with both parents. 6 Pre- Boatman appellate decisions shed some light on who may be a primary parent. In a same-sex case, Ramey v. Sutton , 7 Ms. Ramey was characterized by the Oklahoma Supreme Court as the primary caregiver for the following reasons: During the first four years of their child’s life, Ramey was the primary caregiver due to Sutton’s work and sleep sched ule. Ramey assisted in caring for their child following a tonsil lectomy as well as providing

Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

JANUARY 2026 | 53

THE OKLAHOMA BAR JOURNAL