Black v. Glawson

LEWIS, Judge.

This case concerns the trial court’s decision to award custody of Brittney Dawn Hutchins to defendant Mark Hutchins (hereinafter “Hutchins”), her biological father. Plaintiffs are relatives of Kimberly Dawn Glawson (hereinafter “Glawson”), Brittney’s mother, who is now deceased. Before her death, Glawson indicated that she wanted plaintiffs to have custody of her children. Plaintiffs filed an action for custody in November 1989. In June 1992 the court entered an order declaring Hutchins to be the biological father of Brittney and awarding him custody. Plaintiffs now appeal.

The sole issue to be addressed in this case is the proper standard to be used in determining whether to award custody of a *444minor child to a natural parent or to a third party. The standard actually used by the trial court is somewhat ambiguous. Plaintiffs contend the court erroneously believed it had to award custody to the natural parent absent a finding of unfitness. Hutchins replies that the court correctly awarded custody based upon the best interest of the child.

According to the relevant statute,

[a]n order for custody of a minor child entered pursuant to this section shall award the custody of such child to such person, agency, organization or institution as will best promote the interest and welfare of the child.

N.C.G.S. § 5043.2(a) (1987). Prior to the enactment of the present version of this statute, the Supreme Court held that custody must be awarded to a natural parent absent a finding of unfitness. Jolly v. Queen, 264 N.C. 711, 142 S.E.2d 592 (1965). When Jolly was decided, the statute read that a court “may” award custody based upon the best interest of the child. See N.C.G.S. § 17-39.1 (1965) (repealed in 1967). After the Jolly decision, the legislature amended the statute to state that a court “shall” award custody based upon the best interest of the child. We believe the Jolly Court was able to reach its result because, under the “may” version of the statute, a court was not limited to a strict “best interest and welfare” analysis. It could impose other requirements, such as unfitness of the natural parent, in addition to the best interest test. Now, with the statutory change, a court must award custody based only upon the best interest and welfare of the child. A court must have discretion to determine the best interest of a child, and should not be restricted to awarding custody to a natural parent in the absence of a finding of unfitness.

Moreover, recent decisions of this Court discussing this statute and the best interest test indicate that it is not necessary to prove a natural parent unfit in order to award custody to a third party. Although there is a rebuttable presumption in favor of a natural parent, see, e.g., Best v. Best, 81 N.C. App. 337, 344 S.E.2d 363 (1986), it is not necessary to prove unfitness in order to overcome the presumption. Id. We note that the statute itself imposes no presumption at all in favor of a natural parent, but find that we are bound by the decisions of this Court imposing such a presumption.

*445In the case at hand, the trial court’s order refers to a presumption in favor of defendant and the fact that the presumption has not been rebutted. The court concludes that the best interest of the child requires that she be placed with her father. We see no reason to disturb this finding. We have reviewed plaintiffs’ other contentions and find them to be meritless.

The order of the trial court is

Affirmed.

Judge WYNN concurs. Judge McCRODDEN concurs in a separate opinion.