Shannon Floyd appealed an order awarding custody of his three children to their maternal grandmother. The children had been removed from their mother’s custody after a drug overdose, and the grandmother petitioned for custody; Floyd, who had not yet legitimated the children, counterclaimed. The trial court awarded the grandmother custody after finding serious parental failings, including drug-related conduct and violence toward the mother, and stated that it had applied the best-interest standard. The Court of Appeals of Georgia vacated and remanded because the order did not clearly make the findings required by Georgia law. A parent has a preferred right to custody over a third-party relative unless the relative proves by clear and convincing evidence that parental custody would cause physical or significant, long-term emotional harm. Only after that presumption is overcome does the court weigh whether third-party custody best serves the children’s welfare. The trial court’s references to emotional harm did not show whether it found the required type of harm, and it was unclear whether the court considered the four Clark factors concerning caretakers, psychological bonds, continuing parental interest, and special needs. The appellate court therefore returned the case for reconsideration under the correct framework and did not address Floyd’s remaining arguments. Judge Miller concurred in the judgment only.