An interesting decision out of Suffolk County recently established custodial rights of a non-biological parent who was part of a polyamorous relationship. In Dawn M. v. Michael M., the court essentially affirmed the validity of a non-traditional family composed of two women and one man. Though their names have been revealed in the media, for our purposes we will call the family members Mom 1, Mom 2, Dad, and Child. Mom 1 and Dad were a married couple who had attempted to conceive with great difficulty. They utilized in vitro fertilization, but unfortunately Mom 1 miscarried.