In December 1990, in Norman v. McMahon the State Court of Appeals invalidated a portion of former MPP §45-101(ee) (current MPP §45-101(r)(1)) that had determined former stepparents to be relatives for FC purposes. The court in Norman held that a former stepparent was not a relative.

MPP §45-203.21 states that in order for a child to be eligible for state FC benefits, the child shall be placed with a nonrelative or be living with a nonrelated legal guardian. As a result of the Norman case, former stepparents were eligible to receive FC benefits for former stepchildren because they were nonrelatives.

The Norman case was based on an interpretation of W&IC §11400(m) that cross-referenced a narrow definition in a federal statute. Assembly Bill 2773 modified W&IC §11400(m) by removing the cross reference to the federal statute and replacing it with a list of those persons considered to be relatives for FC purposes, including former stepparents. Accordingly, the Norman case no longer applies to the definition of a relative in the state FC program. All persons (including former stepparents) listed in MPP§45-101(r)(1) are relatives for both state and federal FC purposes.