What is the test for a father who has never had any significant custodial relationship with his child?

"Parental rights do not spring full-blown from the biological connection between parent and child. They require relationships more enduring." (Lehr v. Robertson (1983) 463 U.S. 248, 260, 103 S.Ct. 2985, 2992, 77 L.Ed.2d 614; emphasis added.) In Lehr, the United States Supreme Court held New York's legislature was not constitutionally compelled to listen to fathers who "never had any significant custodial, personal, or financial relationship" regarding their child's best interests. (Id. at p. 262, 103 S.Ct. at p. 2993.)