The Appellate Group

Guanuna v. Sawatzki

Guanuna v. Sawatzki, 2026 UT App 130 (Christiansen Forster, J)

Criminal

The Utah Court of Appeals held:

(1) There is no support in the law for a court in a paternity case to adjudicate one man as the father and give another man guardianship of a child.
(2) The estoppel provision in Utah Code § 81-5-608 cannot be used by an unmarried biological father to force the court to recognize genetic test result and strip a presumed father of his legal paternity.
(3) To be legally binding, a voluntary declaration of paternity must comply strictly with the requirements of Utah Code § 81-5-302.

Read the full court opinion