Best Interests of the Child With Respect to Grandparent Visitation in Maryland

In Fairbanks v. McCarter, 330 Md. 39, 622 A.2d 121 (1993), the Court of Appeals discussed the factors to be considered when determining the best interests of the child with respect to grandparent visitation: Common experience dictates that visits with grandparents often offer benefits to children which cannot be derived from any other relationship. Mimkon v. Ford, 66 N.J. 426, 332 A.2d 199, 204-205 (1975)... As a general proposition, visitation awarded to adults is not for their gratification or enjoyment, but to fulfill the needs of the child.... The trial court must concern itself solely with the welfare and prospects of the child. In so doing, the court should assess in their totality all relevant factors and circumstances pertaining to the grandchild's best interests. These would include, but not be limited to: the nature and stability of the child's relationships with its parents; the nature and substantiality of the relationship between the child and the grandparent, taking into account frequency of contact, regularity of contact, and amount of time spent together; the potential benefits and detriments to the child in granting the visitation order; the effect, if any, grandparental visitation would have on the child's attachment to its nuclear family; the physical and emotional health of the adults involved; and the stability of the child's living and schooling arrangements. (Fairbanks, supra, 330 Md. at 49-50.)