In the matter of P.G. v. A.C. and D.H. (case no.: 947 WDA 2020), the Pennsylvania Superior Court has clarified the distinction between a long-term babysitter and someone who can obtain the status of in loco parentis.

In P.G. the appellant, P.G., was good friends with the child’s mother, A.C. (the father, D.H., did not participate in the case). While P.G. and A.C. had a couple of sexual encounters, their relationship was largely, and ultimately, platonic.