In Charisma R. v. Kristina S. (2009) 175 Cal.App.4th 361, the Court rejected a biological mother's constitutional challenge to application of the parentage presumption to her former same-sex partner, reasoning: "Biological mother's claim is essentially that as the biological mother, and in the effective absence of a biological father, she has a fundamental right to decide whether the child has a second parent. However, she presents no authority or reasoned argument that a state infringes on a biological parent's substantive due process rights by extending parental status to a nonbiological parent in the circumstances of this case." (Id. at p. 388.)