In Petersen v. Rogers, 337 N.C. 397, 445 S.E.2d 901 (1994), our Supreme Court recognized that parents have a constitutionally protected right to the custody, care and control of their child, absent a showing of unfitness to care for the child. Accord Bivens v. Cottle, 120 N.C. App. 467, 462 S.E.2d 829 (1995), appeal dismissed, 346 N.C. 270, 485 S.E.2d 296 (1997). After Petersen, our Supreme Court in Price v. Howard, supra, held that the "protection of the parent's interest is not absolute" and "'the rights of the parents are a counterpart of the responsibilities they have assumed.'" Price, 346 N.C. at 76, 484 S.E.2d at 533 (quoting Lehr v. Robertson, 463 U.S. 248, 257, 77 L. Ed. 2d 614, 624, 103 S. Ct. 2985 (1983)). The Court reasoned that a parent's right to child custody is also based on the presumption that the parent will act in the best interests of the child. See Price, 346 N.C. at 79, 484 S.E.2d at 534. Thus, the Court held that a parent may lose the constitutionally protected paramount right to child custody if the parent's conduct is inconsistent with this presumption or if the parent fails to shoulder the responsibilities that are attendant to rearing a child. See id. If a parent does indeed act inconsistently with the protected status, a court should apply the "best interests of the child" test in resolving a custody dispute between that parent and a nonparent. See id. In Price, the Supreme Court pointed out the type of conduct that could result in the loss of a parent's protected status. For example, unfitness, neglect and abandonment may constitute conduct inconsistent with a parent's protected status. See id. Further, other types of conduct, viewed on a case-by-case basis, may also prove to be inconsistent with a parent's protected status. See id. at 79, 484 S.E.2d at 534-35. The Court in Price considered one type of conduct in particular which may show that a parent acted inconsistently with her protected status--voluntary abandonment of a child.