Grandparents did not have standing to seek custody of child since the fact that the mother signed a consent to guardianship, which was either done under a misapprehension as to the consent’s meaning or was simply recanted within a week of its execution, without a change in the minor child’s physical custody, was not enough to effect a waiver, and the grandparents did not have physical possession of the child when they filed their petition.  Groff v. Groff.
 Maternal grandparents did not waive their right to intervene in proceedings on father’s petition to modify child custody based on their failure to intervene in prior custody litigation.  In re Feig.
 Maternal grandparents standing to intervene in proceedings on father’s petition to modify child custody was supported by sufficient evidence.  In re Feig.
 Where custodial parent surrendered her custodial possession by delivering the child to her parents, the child’s maternal grandparents, the grandparents did not have standing to seek custody under subdivision (b)(2) of this section in a custody determination against the non-custodial parent.  In re Gustafson.
  The child’s grandparents failed to demonstrate standing where the evidence disclosed only that the father and the child lived with the grandparents before the father was awarded custody that subsequently, the child lived with the natural father, and the petition for custody was filed while the child was visiting his grandparents.  Butler v. Butler.
 Petitioner, the child’s parental grandmother, had standing to file her custody petition because child’s natural father voluntarily surrendered her care and custody to the petitioner while the child was still an infant, and the petitioner’s care and custody continued uninterrupted for approximately three years, the child was not in the physical custody of her natural father, additionally, the record clearly established that child’s natural mother abandoned the child while she was an infant.  McKerr v. Bozarth.
 If boyfriend proves to be the actual father of child, and he had physical custody of the boy at time of mother’s death, grandparents are without standing to file custody petition.  Lewis v. Newsome.
 Grandparents have been held to have standing under subdivision (b)(2) of this section In re Black.

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