People ex rel. Wilson v. Wilson
This case concerns an appeal from a Family Court judgment in New York County, dated October 29, 1975, which had dismissed a mother's petition for a writ of habeas corpus seeking to regain custody of her 15-year-old child from the child's grandmother. The Appellate Division reversed the Family Court's decision, finding that while extraordinary circumstances existed (mother's voluntary surrender of custody, child's long-term residence with grandmother, mother's unwed status and living situation, and past emotional issues) that warranted applying the 'best interest of the child' standard, the original hearing was inadequate. The court noted deficiencies such as the child not testifying, restricted inquiry into the mother's relationship with the child, and limited elaboration by a psychiatric worker. Therefore, the matter was remanded for a new hearing to properly determine the child's best interest, to be conducted before a different judge. Justice Kupferman concurred with the 'best interest' standard but dissented on the need to assign a different judge.