Atonio v. Wards Cove Packing Co.

How later courts describe this case

• affirming adoption decree where, despite presumption favoring noncustodial father, trial court found by clear and convincing evidence that child would suffer significant psychological harm from removal from pre-adoptive home
• "Nothing in the 1991 Act ... modifies the central holding of Wards Cove ..."
• applying Rufo flexible standard to situations in which "a decree seeks pervasive change in long established practices affecting a large number of people, and the changes are sought to vindicate rights of a public nature"
• "The Act significantly modifies the rules that the Supreme Court announced in Wards Cove."
• under D.C.Code § 17-305(a) the Court of Appeals "must give great deference to the trial court’s factual findings and may not set them aside unless it appears they are plainly wrong or without any evidentia-ry foundation”
• under D.C.Code § 17-305(a) the Court of Appeals "must give great deference to the trial court's factual findings and may not set them aside unless it appears they are plainly wrong or without any evidentiary foundation"