ion where parents were found unable to care for child, recognizing that continuity of relationships with third parties may be important to child and that the courts have increasingly recognized the importance of these relationships but not addressing best interests standard in other contexts); In re Guardianship of Palmer, 81 Wn.2d 604, 503 P.2d 464 (1972) (recognizing that children can form bonds with third parties and addressing best interests of child when determining whether to restore custody to parents who had previously been found unfit without discussing how parents' and child's interests must be balanced before parents' rights can be terminated in the first instance); In re Custody of A.C., 124 Wn. App. 846, 103 P.3d 226 (2004) (recognizing child may form important bonds with non-parent and allowing grandmother who had cared for grandchild with son's permission to request visitation under dissolution statutes), remanded for reconsideration, 155 Wn.2d 1011, reversed on remand, 130 Wn. App. 157 (2005); In re Welfare of Harney, 19 Wn. App. 85, 88, 574 P.2d 395 (brief discussion of parties' interests in context of the burden of proof, recognizing that parental rights "are measured against the discharge of parental responsibilities; the welfare of the child is always the primary consideration," and finding parent unable to care for child but not addressing if best interests test applies if parent is not unfit) (citing In re Welfare of Snyder, 85 Wn.2d 182, 532 P.2d 278 (1975)), review denied, 90 Wn.2d 1015 (1978); In re Adoption of B.L.V.B., 160 Vt. 368, 628 A.2d 1271, 1276 (1993) (consensual same sex adoption case involving de facto parent relationship stating that "our paramount concern should be with the effect of our laws on the reality of children's lives," and applying best interests of the child test, holding that natural mother's rights need not be terminated for de facto same-sex parent to adopt the child). The appellants also argue that the father failed to establish a relat

ion where parents were found unable to care for child, recognizing that continuity of relationships with third parties may be important to child and that the courts have increasingly recognized the importance of these relationships but not addressing best interests standard in other contexts); In re Guardianship of Palmer, 81 Wn.2d 604, 503 P.2d 464 (1972) (recognizing that children can form bonds with third parties and addressing best interests of child when determining whether to restore custody to parents who had previously been found unfit without discussing how parents' and child's interests must be balanced before parents' rights can be terminated in the first instance); In re Custody of A.C., 124 Wn. App. 846, 103 P.3d 226 (2004) (recognizing child may form important bonds with non-parent and allowing grandmother who had cared for grandchild with son's permission to request visitation under dissolution statutes), remanded for reconsideration, 155 Wn.2d 1011, reversed on remand, 130 Wn. App. 157 (2005); In re Welfare of Harney, 19 Wn. App. 85, 88, 574 P.2d 395 (brief discussion of parties' interests in context of the burden of proof, recognizing that parental rights "are measured against the discharge of parental responsibilities; the welfare of the child is always the primary consideration," and finding parent unable to care for child but not addressing if best interests test applies if parent is not unfit) (citing In re Welfare of Snyder, 85 Wn.2d 182, 532 P.2d 278 (1975)), review denied, 90 Wn.2d 1015 (1978); In re Adoption of B.L.V.B., 160 Vt. 368, 628 A.2d 1271, 1276 (1993) (consensual same sex adoption case involving de facto parent relationship stating that "our paramount concern should be with the effect of our laws on the reality of children's lives," and applying best interests of the child test, holding that natural mother's rights need not be terminated for de facto same-sex parent to adopt the child). The appellants also argue that the father failed to establish a relat