What is the basis for a custody order issued by the juvenile court?

Mother's second legal contention is also fatally flawed. She repeatedly maintains in the briefing that without a court finding she was an unfit mother, there was no lawful basis for the court's refusal to award her sole legal and physical custody of the children. Mother argues that upon Father's death, physical and legal custody should have automatically reverted back to her. However, all the legal authority she relies upon relates to custody orders arising from a family law court divorce decree. (See, e.g., Schammel v. Schammel (1894) 105 Cal. 258.) She offers no analysis or reason why this body of case law should also apply to custody orders generated by the juvenile court as a

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