4.4.5 Non-Parent Custody

The Louisiana Supreme Court has held that the Evans and Bergeron standards apply equally to non-parent custody cases under La. C.C. art. 133.1  Only if the judgment awarding custody to a non-parent is a considered decree will the heightened standard of Bergeron apply.

• 1Tracie F. v. Francisco D., 2015-1812 (La. 3/15/16), 188 So. 3d 231.