## Facts

- Donald L. Parris (Father) and Ruth H. Parris (Mother) married in 1979 and had a son, Maxfield, born in 1980.
- The family lived on Hilton Head Island; Mother worked full-time as a highly successful realtor, while Father pursued real estate and business ventures and was less financially successful in recent years.
- In 1990, after financial difficulties, Mother sought a divorce; Father moved out and filed an action seeking custody; Mother counterclaimed for full custody.
- Mother received temporary custody pending a final hearing.
- After trial, the family court found both parents fit and entered a final order granting Father permanent custody, with visitation to Mother.
- A guardian ad litem and a court-appointed psychologist concluded both parents were fit custodial parents and characterized the case as a close call.
- The family court credited evidence that, before litigation, Father was more involved in Maxfield’s day-to-day care, including medical transport, extracurricular activities, school involvement, morning routines, and regular meal preparation.

## Issues

1. Whether awarding custody to Father reflected gender bias against a full-time working mother.
2. Whether the family court erred by declining to award joint custody.

## Decision

- The Supreme Court of South Carolina affirmed the family court’s award of permanent custody to Father.
- The court held the record did not support Mother’s claim that the custody decision was based on gender bias or on her full-time employment.
- The court held the family court did not abuse its discretion in denying joint custody.

## Legal Principles

- Child custody is determined by the child’s best interests under the totality of the circumstances.
- Custody decisions must be gender-neutral; a parent’s sex or the fact that a mother works full-time does not create a presumption against custody.
- Evidence of a parent’s historical day-to-day caregiving may support a best-interests finding when both parents are otherwise fit.
- Joint custody is not required; the family court may award sole custody when it finds a clearer custodial arrangement better serves the child’s interests.

## Conclusion

The court upheld an award of sole custody to Father because the decision rested on best-interests findings grounded in caregiving history rather than stereotypes about working mothers, and it found no abuse of discretion in declining to order joint custody.


Parris v. Parris, 460 S.E.2d 571 (S.C. 1995)