This was a custody dispute between a natural mother and a foster mother. Gina Marie was placed with the natural mother, and now the court reexamined its findings based on the Jeffreys case. There was a finding that while M was an adequate mother from the standpoint of physical needs, it seems that an emotional void existed between the child and the natural mother. When tested for IQ in 1975 the child scored 113. When tested again in 1977, the child scored 84. An expert from Yale was called in and testified that the child was mourning the loss of her mother. The family court awarded custody to the foster mother.

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