context: . This court's child custody cases manifest a tension between older decisions that apply a "fitness" test and more recent ones that focus instead on the "best interests of the child."
citation_a.signal: see also
citation_a.parenthetical: recognizing the two lines of child custody cases but declining to resolve conflict
citation_a.sentence: Compare Johnson v. Lloyd, 211 A.2d 764, 765 (D.C. 1965) ("The established rule in this jurisdiction is that one who would withhold a child from its natural parent has the burden of proving that the natural parent is unfit to have custody and that the child’s welfare compels awarding custody to the nonparent.”) with In re K.A., 484 A.2d 992, 997 & n. 2 (D.C.1984) (applying "best interests of the child” test to termination of parental rights where natural father refused to consent but never had had custody of child); see also Shelton, 526 A.2d at 580 n. 3 (recognizing the two lines of child custody cases but declining to resolve conflict).
citation_b.signal: no signal
citation_b.identifier: 211 A.2d 764, 765
citation_b.parenthetical: "The established rule in this jurisdiction is that one who would withhold a child from its natural parent has the burden of proving that the natural parent is unfit to have custody and that the child's welfare compels awarding custody to the nonparent."
citation_b.sentence: Compare Johnson v. Lloyd, 211 A.2d 764, 765 (D.C. 1965) ("The established rule in this jurisdiction is that one who would withhold a child from its natural parent has the burden of proving that the natural parent is unfit to have custody and that the child’s welfare compels awarding custody to the nonparent.”) with In re K.A., 484 A.2d 992, 997 & n. 2 (D.C.1984) (applying "best interests of the child” test to termination of parental rights where natural father refused to consent but never had had custody of child); see also Shelton, 526 A.2d at 580 n. 3 (recognizing the two lines of child custody cases but declining to resolve conflict).