In recent years, courts have been faced with deciding what constitutes "parental fitness" for custody purposes in light of society's changing mores and values. In attempting to define the role that a parent's sexual lifestyle plays in a custody or visitation dispute, courts across the country have lost sight of their ultimate responsibility - to protect the best interests of the child. Instead, courts often seem more concerned with protecting the sexual freedom of unmarried parents than in contemplating the impact cohabitation may have on children. The Court of Appeals of Virginia is no exception.

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