The Supreme Court has adopted a common law doctrine of “intent-based parentage” as a fifth way to establish parentage in Pennsylvania. In the case that was decided, a couple in a same-sex marriage had arranged to have a child through assistive reproductive technology and the artificial insemination of one of the spouses. The presumption that a child born during a marriage is the child of both parents did not apply because the parties separated and began divorce proceedings before the birth of the child, and neither the various documents that were signed by one or both of the parties nor the testimony of the parties were sufficient to establish parentage by contract. Because there was extensive evidence that the parties mutually intended to conceive and raise a child, the Supreme Court extended Pennsylvania’s parentage jurisprudence to adopt a doctrine of intent-based parentage, allowing a spouse who is not a biological parent to become a parent of a child which is not born during the marriage and for which there was no opportunity to adopt and no express contract. Glover v. Junior, ___ A.4th ___, ___ Pa. ___, 9 EAP 2024 (3/20/2025).