What is the test for a parent who has no physical custody of their child and only has a right to visitation?

MultiRegion, United States of America

The following excerpt is from Berman v. Mcmanus, No. 2:11-cv-000635 MCE KJN PS (E.D. Cal. 2011):

"The Fourteenth Amendment's Due Process Clause protects parents' well-established liberty interest in the 'companionship, care, custody, and management of [their] children.'" James, 606 F.3d at 651 (modification in original) (citing Lassiter v. Dep't of Soc. Servs., 452 U.S. 18, 27 (1981)). Parents with no legal or physical custody, but merely visitation

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