A 2025 decision from the California Court of Appeal (Balandran v. Balandran (2025) 113 Cal.App.5th 858.) is a significant victory for parental autonomy, particularly in the sensitive context of Family Code section 3102 (providing relatives of deceased parent visitation with children). The Conflict between Mom and In-Laws After the untimely passing of David Balandran from COVID-19, his wife Felicia—the mother of their two young daughters—continued to facilitate voluntary visitation between the children and their paternal grandparents. In most months, the