1. If there was a pending action involving the child, the court may have allowed the grandparents standing to pursue visitation, and in the course of evaluating the particular facts, ordered such visitation. 2. In limited circumstances, courts granted standing and visitation to grandparents even when there was no other matter before the court. 3. Some courts granted standing to grandparents to seek visitation with their grandchildren and then conducted a best interest analysis. 4. Lastly, some courts denied grandparents standing to request visitation outright and never addressed whether or not the visitation was in the child's best interests.