The following excerpt is from Sanjivini K., Matter of, 391 N.E.2d 1316, 418 N.Y.S.2d 339, 47 N.Y.2d 374 (N.Y. 1979):
If we were only concerned with deciding custody the prolonged separation might be entitled to greater weight. In Matter of Bennett v. Jeffreys (supra) we held that a mother who permitted her child to remain with a family friend for an extended period might be denied the right to regain custody, without regard to fault, if disruption of the existing custody would not be in the child's best interest. That case involved an informal arrangement and, we noted (at p. 545, 387 N.Y.S.2d at p. 824, 356 N.E.2d at p. 281) "as an unsupervised private placement, no statute is directly applicable, and the analysis must proceed from
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