No Express Finding of Child Harm Required for Mental-Health and Adultery Considerations in Albright Custody Analysis: Commentary on Edwards v. Edwards

I. Introduction

This decision from the Supreme Court of Mississippi addresses three recurring and sensitive themes in family law:

• How a parent’s mental health should be weighed under the Albright best‑interest factors in a child‑custody dispute.
• How a parent’s post‑separation adultery and the children’s exposure to multiple romantic partners affect the moral fitness factor.
• When a chancellor’s courtroom comments and tone cross the line into actual or apparent bias requiring recusal.

Aubrey and Brad Edwards, married in 2013, are parents of two young children born in 2017 and 2018. The marriage deteriorated amid conflict over domestic roles, Brad’s alleged alcohol use and controlling behavior, and Aubrey’s well‑documented history of depression and suicidality. After separation in April 2020, Brad obtained a temporary custodial arrangement and ultimately was awarded primary physical custody, with joint legal custody, following an Albright analysis that slightly favored him on the mental‑health and moral‑fitness factors.

Aubrey appealed, arguing essentially:

• The chancellor misapplied the mental‑health factor by overemphasizing her depression and history of suicide attempts without proof that it impaired her parenting.
• The chancellor misapplied the moral‑fitness factor by treating her post‑separation relationships as a strike against her absent proof of concrete harm to the children.
• The chancellor should have granted a new trial and/or recused himself because his comments and questioning showed bias against her.

The Supreme Court affirmed in all respects, using the case to clarify and reinforce several points in Mississippi custody jurisprudence:

• No specific written finding is required that a parent’s mental illness has detrimentally impacted the child before that illness may weigh against the parent under the Albright mental‑health factor.
• Adultery and children’s exposure to multiple partners may legitimately tip the moral‑fitness factor, even without detailed findings of concrete harm, so long as adultery is not used merely as a punitive sanction.
• The bar for mandatory recusal based on a chancellor’s comments is high; even “concerning” or insensitive remarks will not, without more, require disqualification.

II. Summary of the Supreme Court’s Opinion

A. Factual and Procedural Background

Key factual points include:

• Aubrey emerged from a childhood marked by hardship, neglect, and violence. She openly admitted suicide attempts at age fourteen and again in 2019 and testified to ongoing struggles with depression and anxiety. Two of her relatives had died by suicide.
• Despite this, she maintained full‑time employment, broke ties with unstable relatives to build a more stable life, and relied on friends and coworkers rather than family for emotional support.
• Brad was embedded in a stable, extended family network; his parents lived next door and provided regular assistance with the children. He described the family as “very close‑knit and loving.”
• The April 2020 crisis precipitating separation involved an argument over a cell phone, Aubrey locking herself in a bathroom, superficial self‑inflicted cuts, and a hospital visit where she was assessed as at “high risk for suicide” given her past history and psychosocial stressors, but not kept for inpatient treatment.
• The Mississippi Department of Child Protection Services (CPS) conducted at least two home visits (one unannounced) and found no concerns about the home, children’s well‑being, or Aubrey’s caregiving.

Brad filed for divorce on grounds including cruel and inhuman treatment; Aubrey counterclaimed for cruel and inhuman treatment and habitual drunkenness, with irreconcilable differences as an alternative ground. A temporary order provided for alternating 15‑day physical custody blocks with the children remaining in the marital home. The parties then agreed to an irreconcilable-differences divorce, leaving custody and support to be decided by the chancellor.

After an Albright best‑interest analysis, the chancellor found that the mental‑health and moral‑fitness factors slightly favored Brad and accordingly awarded him primary physical custody, with joint legal custody. Aubrey appealed.

B. Issues on Appeal

1. Did the chancellor err in the Albright analysis by (a) improperly weighing Aubrey’s mental health against her, and (b) improperly weighing Aubrey’s moral fitness (particularly her relationships) against her?
2. Did the chancellor err in denying Aubrey’s motion for a new trial in light of the alleged misapplication of the moral‑fitness factor?
3. Did the chancellor err in denying Aubrey’s motion for recusal, given his comments and questioning during trial?

C. Holding

The Supreme Court of Mississippi:

• Affirmed the chancellor’s Albright findings, holding that the mental‑health and moral‑fitness factors could permissibly be found to slightly favor Brad.
• Affirmed the denial of Aubrey’s motion for a new trial, as it added nothing beyond the already‑rejected moral‑fitness challenge.
• Affirmed the denial of the motion for recusal, finding that the chancellor’s comments, while sometimes “concerning,” did not meet the standard for required disqualification.

III. Detailed Analysis

A. Standard of Review and the Albright Framework

The Court reiterates the familiar rule that appellate review in custody cases is highly deferential:

• The appellate court gives deference to the chancellor’s factual findings, asking whether they are supported by “substantial evidence.” Floyd v. Floyd, 949 So. 2d 26, 28 (Miss. 2007).
• Reversal is warranted only if the chancellor is “manifestly wrong” or applied an erroneous legal standard. Id. (citing Powell v. Ayars, 792 So. 2d 240, 243 (Miss. 2001)).
• Credibility determinations and weighing of evidence belong to the chancellor, not the appellate court. Powell, 792 So. 2d at 243 (citing Chamblee v. Chamblee, 637 So. 2d 850, 860 (Miss. 1994)).

The core substantive standard is that the “polestar consideration” in custody cases is the “best interest and welfare of the child.” Albright v. Albright, 437 So. 2d 1003, 1005 (Miss. 1983). To that end, the Court re‑lists the familiar twelve Albright factors, including:

• Age, sex, health of the child.
• Continuity of care before separation.
• Parenting skills and willingness/ability to provide primary care.
• Employment and related responsibilities.
• Physical and mental health and age of the parents.
• Emotional ties between parent and child.
• Moral fitness of each parent.
• Home, school, and community record of the child.
• Child’s preference (if appropriate).
• Stability of home environment, and other relevant factors.

The Court re‑emphasizes:

The Albright factors are a guide. They are “not the equivalent of a mathematical formula.” Lee v. Lee, 798 So. 2d 1284, 1288 (Miss. 2001).

And on review:

“[T]his Court reviews the evidence and testimony presented at trial under each factor to ensure the chancellor’s ruling was supported by the record.” Hollon v. Hollon, 784 So. 2d 943, 947 (Miss. 2001).

Thus, the Court’s task is not to re‑weigh the evidence but to confirm that the chancellor’s Albright factor‑by‑factor conclusions are supported by substantial evidence and that the correct legal standards were used. Against that backdrop, the Court considers Aubrey’s attacks on the mental‑health and moral‑fitness findings.

B. The Mental-Health Factor under Albright

1. The evidence: Aubrey’s history and present functioning

The record, as summarized by the Court, painted a nuanced mental‑health picture:

• Aubrey acknowledged a long history of depression, including post‑partum depression after the 2018 birth, and suicide attempts as a teen and again in 2019.
• She described proactive engagement with mental‑health treatment and testified that she was seeing a counselor only on an as‑needed basis at the time of trial.
• CPS conducted at least two visits and reported no concerns about her home, the children’s condition, or her caregiving.
• The April 2020 incident involved superficial cuts and a hospital evaluation, after which she was deemed “high risk for suicide” but did not meet the threshold for inpatient admission.

Brad, in contrast, testified that:

• He regarded the April 2020 incident as an “attempted suicide.”
• He was concerned for the children’s safety and described Aubrey’s behavior as manipulative or “a bully tactic” to get what she wanted.

There was no finding that Aubrey had ever harmed or neglected the children, and third‑party witnesses (friends, coworkers, CPS) appeared to view her as a capable parent.

2. Aubrey’s legal arguments

On appeal, Aubrey framed the mental‑health issue in two main ways:

1. The chancellor over‑weighted her difficult childhood and the mental‑health problems and suicides of her relatives—factors she contended were irrelevant to her actual parenting capability.
2. The chancellor erred, she argued, by failing to make a specific finding that her depression had a detrimental impact on the children or impaired her parental abilities. She suggested that some Court of Appeals cases effectively required such a finding when mental illness was used to weigh the factor against a parent.

She also warned that if the decision were affirmed, it would create a de facto requirement of “perfect mental health” for any parent seeking custody.

3. Treatment of background family mental-health evidence

As to her first argument, the Supreme Court notes that when questions at trial ventured into suicides by Aubrey’s relatives, Aubrey’s objections were sustained. The chancellor expressly observed:

“[W]hat our family members may do will not impact how we parent” and “part of the equation is not what family members do.”

The Court cites Garner v. Garner, 283 So. 3d 120, 140 (Miss. 2019), for the proposition that in child‑custody matters the chancellor must consider all relevant factors, but also has the responsibility to “determine ultimately what weight and worth to afford any particular aspect of proof” (quoting Johnson v. Johnson, 872 So. 2d 92, 95 (Miss. Ct. App. 2004)).

Because the chancellor limited the role of relatives’ mental‑health histories and sustained objections, the Court holds this issue without merit.

4. The central doctrinal point: No required express finding of “detrimental impact”

The more significant legal question concerns the level of specificity required in a chancellor’s written findings when mental health is weighed under Albright.

The Court acknowledges its long‑standing preference for detailed, written Albright findings but notes a mixed history on whether omissions are reversible error. It cites:

• Huseth v. Huseth, 135 So. 3d 846 (Miss. 2014), which held that while detailed analysis is preferred, failure to conduct an exhaustive factor‑by‑factor exposition is not automatically reversible when the record indicates the chancellor weighed the factors based on the evidence presented.
• Sobieske v. Preslar, 755 So. 2d 410 (Miss. 2000), as part of the line of cases dealing with the sufficiency of written Albright findings.

Most importantly, the Court relies on its recent decision in Kerr v. Kerr, 323 So. 3d 462 (Miss. 2021), to reiterate:

A chancellor is not required to make a specific written finding that a parent's mental-health disorder detrimentally impacted the child.

The Court further quotes Johnson v. Gray, 859 So. 2d 1006, 1013–14 (Miss. 2003), emphasizing that the chancellor, as fact‑finder, “has the ultimate discretion to weigh the evidence the way he sees fit,” and Hayes v. Rounds, 658 So. 2d 863, 866 (Miss. 1995), for the principle of substantial deference to a chancellor’s supported findings.

Applied here:

• The chancellor heard extensive testimony about Aubrey’s mental health, her improvements, corroboration by friends and coworkers, CPS’s lack of concerns, and the hospital’s “high risk for suicide” notation.
• In a 29‑page opinion, he addressed each Albright factor and concluded that the mental‑health factor marginally favored Brad.
• The chancellor did not explicitly find that Aubrey’s mental illness had harmed the children or impaired her parenting ability, but clearly considered her mental‑health trajectory, the recent suicidal crisis, and Brad’s stated concerns for safety.

The Supreme Court candidly notes:

“[W]hile it would have been helpful to this Court to see the specific finding, because the decision was supported by substantial evidence, we find no reversible error.”

In other words, the absence of an explicit “detrimental impact on the children” finding does not invalidate the chancellor’s conclusion that, all things considered, Brad had a slight advantage under the mental‑health factor.

5. Significance of this clarification

This holding does not create a new rule so much as it confirms and strengthens the direction set in Kerr:

• There is no categorical requirement that a chancellor tie a parent’s mental illness to specific, documented harm to the child before that diagnosis can weigh in the Albright analysis.
• Mental health remains part of a totality‑of‑the‑circumstances test. A chancellor may legitimately consider factors such as a recent suicide attempt or ongoing significant risk, even when the parent is in treatment and outside observers (like CPS) report adequate parenting.
• However, the Court stresses that this does not impose a standard of “perfect mental health” for custody. Rather, it affirms the chancellor’s broad discretion to assess risk and stability based on all credible evidence.

As a practical matter, Edwards signals that on appeal, challenges to the weight assigned to mental‑health evidence face a steep climb. Unless a chancellor’s conclusion is wholly unsupported or based on an erroneous legal standard (for example, treating any diagnosis as an automatic disqualifier), the Supreme Court will rarely interfere.

C. The Moral-Fitness Factor: Adultery and Children’s Exposure

1. The evidence of Aubrey’s relationships

The record indicates:

• Aubrey engaged in multiple post‑separation romantic relationships. She conceded as much.
• She testified that she generally avoided exposing the children to these relationships, but there were instances where they spent time with at least one boyfriend.
• The chancellor found that Aubrey had “adulterous relationships with many men” and that “[t]he evidence indicates the children's exposure to a number of these men.”
• The chancellor characterized Aubrey’s testimony about these relationships as “cavalier,” including her recounting of the children’s positive comments about her current boyfriend; he wrote that she “paraded around” those sentiments.

The chancellor concluded that the children’s exposure to these relationships “might confuse” them, “as if what has occurred between her husband and herself wasn't enough.”

2. Legal framework: adultery and moral fitness

The Supreme Court reaffirms several important principles:

• “Marital fault may not be used as a sanction when applying the Albright factors.” In other words, custody cannot be used to punish adultery.
• However, adultery is relevant when evaluating moral fitness: it can be an “unwholesome influence” or an impairment to the child’s best interest, “but on the other hand, may have no effect.” Carr v. Carr, 480 So. 2d 1120, 1123 (Miss. 1985).
• Where it is relevant, adultery should not be given “undue weight.” Brekeen v. Brekeen, 880 So. 2d 280, 286 (Miss. 2004).

Aubrey relied upon Lawrence v. Lawrence, 956 So. 2d 251 (Miss. Ct. App. 2019) (as cited in the opinion), in which the Court of Appeals held it was error to give “considerable weight” to the mother’s extramarital affair when it had “little impact on the children.” In Lawrence, both parents had engaged in affairs, and the husband was also “extremely violent.” There, the question became which parent’s misconduct had the least impact.

3. Distinguishing Lawrence and affirming the factor in Brad’s favor

The Supreme Court rejects Aubrey’s reliance on Lawrence as “misplaced” and distinguishes that case on material grounds:

• In Lawrence, both parents were adulterous and the father was extremely violent, so the custody analysis looked at relative fault and impact between two imperfect parents.
• In Edwards, Aubrey was the only party who admitted extramarital affairs. There is no indication Brad engaged in similar conduct.
• The chancellor found the children were actually exposed to some of these relationships and reasoned that this exposure “might confuse” them.

Given these distinctions, the Court concludes that:

• The chancellor operated within his discretion in allowing Aubrey’s post‑separation relationships to slightly tilt the moral‑fitness factor in Brad’s favor.
• The factor was not treated as a dispositive sanction; indeed, the chancellor himself commented from the bench:

  “Well, that is extra-marital relations, according to Albright. It falls within one factor. You can't screw up custody just for that so‑to‑speak.”

  This shows an awareness that adultery is but one data point in a multi‑factor analysis.

The Supreme Court, therefore, finds Aubrey’s attack on the moral‑fitness finding without merit.

4. Doctrinal impact

Edwards provides several practical clarifications for future cases:

• Post‑separation adultery and children’s exposure to romantic partners can legitimately weigh against a parent under the moral‑fitness factor, even if:
  • the parent does not cohabit with the partner,
  • there is no explicit finding of serious psychological harm, and
  • the parent can point to positive aspects of the relationship.
• However, the scope of that impact must be tied to the children’s welfare—here, potential confusion arising from exposure to “many” men and the emotional turbulence of the marital breakdown.
• Courts remain wary of transforming adultery into an automatic custody penalty; yet they affirm its continuing relevance when there is some demonstrated or reasonably anticipated influence on the children.

D. Motion for New Trial

Aubrey’s motion for a new trial essentially restated her arguments regarding the moral‑fitness factor, contending that the erroneous weighing of that factor justified a retrial. The chancellor denied the motion, and the Supreme Court affirms on the same reasoning used to uphold the original moral‑fitness finding:

• There was no legal error in the chancellor’s application of the moral‑fitness factor.
• There was substantial evidence supporting the chancellor’s assessment of Aubrey’s multiple relationships and the children’s exposure to them.

Because the appellate court already found the underlying moral‑fitness analysis sound, the denial of a new trial was also without merit.

E. Motion for Recusal: Judicial Impartiality and Courtroom Demeanor

1. Governing standard and precedents

The Court reviews recusal through an objective lens. As explained in Johnson v. Gray, 859 So. 2d 1006, 1015 (Miss. 2003) (quoting Buchanan v. Buchanan, 587 So. 2d 892, 895 (Miss. 1991)):

A judge is required to disqualify himself if a reasonable person, knowing all the circumstances, would harbor doubts about his impartiality.

Key components:

• Canon 3 of the Code of Judicial Conduct demands an objective standard for disqualification decisions. Tubwell v. Grant, 760 So. 2d 687, 689 (Miss. 2000).
• There is a strong presumption of impartiality:

  “[T]he presumption is 'that a judge, sworn to administer impartial justice, is qualified and unbiased.'” Buchanan, 587 So. 2d at 895 (quoting Turner v. State, 573 So. 2d 657, 678 (Miss. 1990)).

• The movant bears a “heavy burden” to overcome this presumption by showing evidence sufficient to cause reasonable doubt as to the judge’s impartiality.

The key comparative precedent is Schmidt v. Bermudez, 5 So. 3d 1064 (Miss. 2009), where the Supreme Court held that a chancellor’s combative, demeaning, and discourteous conduct toward a mother—especially during cross‑examination before she had presented her own case‑in‑chief—deprived her of a fair trial and warranted reversal and reassignment.

2. Aubrey’s complaints about the chancellor’s conduct

Aubrey cataloged several episodes as evidence of bias or partiality:

• During Brad’s testimony about Aubrey’s self‑harm threats, the chancellor suggested that if such threats were manipulative, they implied Aubrey would “go to any length to manipulate an issue,” adding commentary such as:

  “[T]his lady needs some help.”

• When probing Brad about Aubrey’s relationships, the chancellor remarked:

  “She may have 15 [boyfriends].”

  and emphasized that extramarital relations fall under a single Albright factor, reflecting simultaneous skepticism toward Aubrey and awareness of doctrinal limits.
• Most strikingly, during Aubrey’s testimony that Brad had raped her on her birthday when their infant was in a crib nearby, the chancellor asked:

  “Do you think that, perhaps, Brad had the belief that you were inclined to want to have sex, and then said, I don't want to, and then you just ended up having it? … Did he hear you say no? Maybe he didn't somehow.”

  These questions suggested skepticism about Aubrey’s perception and the clarity of her lack of consent, potentially signaling a predisposition in Brad’s favor.

Aubrey argued that these and other comments, taken together, showed that the chancellor had moved from neutral fact‑finder to a quasi‑advocate for Brad, requiring recusal.

3. The Supreme Court’s response

The Supreme Court does not ignore the problematic aspects of the record. It expressly states that some of the chancellor’s comments are “concerning,” especially the “this lady needs some help” remark and the comparison to Schmidt, where the trial judge also opined a mother needed psychological help.

However, the Court emphasizes two critical distinctions from Schmidt:

• In Schmidt, the chancellor’s conduct included repeated insults and badgering, such as telling the mother:

  “I think you are sick right now, the way you are doing” and “I think you've got a psychologist with a yo-yo head.”

  The hostility was pervasive and severe enough to undermine the fairness of the trial.
• In Edwards, by contrast, the Supreme Court finds the chancellor engaged in a thorough fact‑finding mission and that any inappropriate comments were more episodic, likely made “in the passion of the fact‑finding mission,” and did not pervade the entire proceeding to the level of Schmidt.

As a result, the Court holds that, though not ideal, the chancellor’s conduct did not rise to the level warranting mandatory recusal. Aubrey failed to carry the “heavy burden” of showing that a reasonable person, fully informed, would seriously doubt the judge’s impartiality.

Accordingly, the recusal issue is found without merit.

IV. Complex Concepts and Legal Terms Simplified

1. Albright factors

In Mississippi, custody is decided based on a list of considerations known as the Albright factors (from Albright v. Albright, 437 So. 2d 1003 (Miss. 1983)). These are not rigid rules but a checklist that helps the court focus on what arrangement best serves the child’s welfare. Each factor can favor one parent, favor the other, or be neutral. The judge then weighs them collectively.

2. “Polestar consideration”

The phrase means that among all competing interests, the child’s best interest and welfare are paramount. Neither the parents’ preferences nor a desire to reward or punish a parent should override this central focus.

3. “Substantial evidence,” “manifest error,” and “abuse of discretion”

• Substantial evidence means enough credible evidence that a reasonable person could rely on it to reach the same conclusion as the trial judge, even if there is contrary evidence.
• Manifest error (or “manifestly wrong”) means an error that is clear and obvious from the record—more than just a reasonable difference of opinion on the facts.
• Abuse of discretion means the judge made a decision outside the range of reasonable choices, or applied the wrong legal standard, not merely that an appellate court might have decided differently.

4. “Moral fitness” under Albright

“Moral fitness” looks at a parent’s behavior and character traits that may affect the child’s development, such as:

• Honesty, integrity, respect for the law.
• Sexual conduct that may expose or confuse children (e.g., frequent overnight partners).
• Substance abuse, criminal behavior, or other lifestyle factors.

It is not intended to allow courts to punish a parent for private moral failings that have no bearing on the child’s well‑being.

5. Adultery and custody

Mississippi courts distinguish between:

• Using adultery as punishment: Not allowed. A parent does not lose custody just because they committed adultery.
• Considering adultery’s effect on the child: Allowed. If the adultery or related behavior (e.g., bringing multiple partners into the child’s life) appears likely to confuse, destabilize, or negatively influence the child, it can legitimately impact the moral‑fitness factor.

6. Recusal and judicial bias

A motion for recusal asks a judge to step aside from a case due to actual or perceived bias. The standard is whether a reasonable person, aware of all the circumstances, would question the judge’s impartiality. Judges are presumed to be impartial, and the party seeking recusal must present strong evidence to the contrary. Not every sharp remark or tough line of questioning meets this standard.

V. Broader Impact and Practical Implications

A. Mental-health issues in custody disputes

Edwards continues a trend in Mississippi law that:

• Legitimizes consideration of a parent’s diagnosed mental illness, suicide history, and ongoing risk in custody decisions, even absent concrete instances of harm to the child.
• Stops short of making a diagnosis or treatment history a per se disqualifier; mental illness must be weighed among all the Albright factors.

For attorneys and parents, this has several consequences:

• Parents with mental‑health histories should be prepared to show not only diagnosis and treatment, but also a track record of stability and safe parenting, possibly with expert testimony, if they want to counter the inference that a recent suicide attempt or severe episode raises risk.
• Opposing parties may leverage mental‑health records and risk assessments (e.g., “high risk for suicide” notations) to argue that the mental‑health factor should favor them, even if child protection agencies have not intervened.
• Chancellors are encouraged, though not compelled, to make explicit findings connecting mental‑health evidence to parenting capacity to facilitate appellate review and minimize perceptions of stigma.

B. Adultery, children’s exposure, and moral fitness

On the moral‑fitness front, Edwards reinforces that:

• Post‑separation conduct is relevant, particularly when it affects the child’s living environment and emotional stability.
• Even absent documented psychological harm, a chancellor may infer that exposure to “many” romantic partners is potentially confusing or destabilizing for young children.
• The key is whether the adultery remains a private adult matter or becomes part of the child’s lived reality (by way of frequent contact, overnights, or blurred family boundaries).

Practically, parents should be aware that:

• Courts scrutinize not only whether a parent has moved on romantically, but how that new relationship is integrated into the children’s lives.
• Carefully managing children’s exposure to new partners, especially in the early phases and in high‑conflict situations, remains important to avoid a negative finding on moral fitness.

C. Judicial comments, courtroom tone, and recusal strategy

From a judicial conduct perspective, Edwards sends a mixed but clear message:

• The Supreme Court is watchful and critical of chancellors whose commentary risks crossing into partiality, as it expressly labeled some remarks here “concerning.”
• At the same time, it maintains a high threshold for reversal or recusal based solely on courtroom comments, reserving that remedy for extreme cases like Schmidt where the judge’s demeanor was pervasively combative and demeaning.

For practitioners:

• Motions for recusal based on isolated or sporadic remarks are unlikely to succeed, especially if raised late and without a full record of persistent hostility or favoritism.
• However, making a clear record of problematic comments can still be important for:
  • Potential appellate review in especially egregious cases.
  • Judicial‑conduct complaints or informal corrective feedback.

VI. Conclusion: Key Takeaways from Edwards v. Edwards

Edwards v. Edwards does not revolutionize Mississippi custody law, but it meaningfully clarifies and reinforces several important points:

1. No Express Child-Harm Finding Required for Mental-Health Factor A chancellor may weigh a parent’s mental illness, including depression and recent suicidality, against that parent under the Albright mental‑health factor without making a specific written finding that the illness has already harmed the child. The focus remains on the totality of the circumstances and the chancellor’s supported assessment of risk and stability.
2. Adultery and Children’s Exposure Legitimately Affect Moral Fitness Adultery cannot be used as a punitive sanction, but it remains relevant in assessing moral fitness, especially where children are actually exposed to multiple romantic partners. Even the risk of confusion or destabilization—rather than documented harm—can justify modestly weighing this factor against the adulterous parent.
3. Strong Deference to Chancellors’ Fact-Finding The decision reaffirms that appellate courts will rarely disturb chancellors’ Albright assessments if there is substantial evidence supporting them, even where the record could arguably support a different result. The chancellor’s role as the primary fact‑finder and credibility assessor is central.
4. High Bar for Recusal Based on Courtroom Comments While some of the chancellor’s remarks were “concerning,” they did not reach the pervasive, demeaning level found in Schmidt v. Bermudez. The Court maintains a robust presumption of judicial impartiality and requires a showing of serious, sustained partiality before ordering recusal or reversal on that basis.

In the broader legal landscape, Edwards underscores the complexity of integrating mental‑health realities and evolving adult relationships into custody decisions. It sends a clear message that Mississippi courts will continue to weigh these issues carefully through the Albright framework, granting considerable discretion to chancellors, while insisting that the best interest of the child—not punishment, stigma, or moralism—remains the polestar.