Prosper Ortega, the biological mother of a child, petitioned to regain custody after a consent order placed the child with Leigh Temple and others. The Court of Appeals of Georgia held that the trial court had not clearly applied the governing custody standard when entering and later amending a temporary order. It also clarified the existing custody position while the matter remained unresolved. The court vacated the temporary order and remanded for the trial court to apply the proper legal standard and make the necessary determinations.