In the case of A.O.V. v. J.R.V., the Virginia Court of Appeals, in an unpublished opinion, held that the trial court properly awarded joint custody of the parties' three minor children to both the gay father and mother. Father was fit to have visitation and the court granted the visitation, but with restrictions and the restrictions were proper. While the court did not bar the father's gay companion from the children's presence, the court could prohibit the father from having his gay companion stay overnight when the children visited and could prohibit the two from engaging in displays of affection in the children's presence.
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