Guardianship of a Minor

From the age of four months, her maternal grandparents 1 had raised the minor, whom we shall call Laurie, as if she were their daughter. At the time of a hearing in January, 1984, on the natural parents’ petition under G. L. c. 201, § 33, to remove the maternal grandmother as Laurie’s guardian, the child was four years old. A judge of a Probate Court, acting upon a clear and convincing evidence standard, found that the natural parents were unfit, and denied the petition to remove the grandmother as guardian. See Santosky v. Kramer, 455 U.S. 745, 768-769 (1982); Custody of a Minor (No. 2), 392…