In Re Guardianship of Palmer

Margaret Spalding, the maternal grandmother and legal guardian of 8-year-old Dawn Palmer, appeals an order of the trial court terminating the guardianship and restoring custody of the child to her natural parents, respondents John and Sharon Palmer.

The trial court terminated the guardianship based on a finding that the unfitness of the natural parents which originally occasioned the guardianship had ceased to exist and that the parents were now fit to assume custody of their child.

The question presented is what rule of law should govern the trial court when parents who have lost custody of…