Virginia's Court of Appeals in Smith v. Smith (unpublished, 10/27/2015) upheld a decision refusing to transfer primary custody to the mother, from a father who turned out not to be the biological father of two of the three children in a paternity test the mother requested. The children had been in the father's custody for several years, he was on their birth certificates and was the only father they had ever known, and those facts were enough to rebut the presumption in favor of natural parents.
The mother's evidence was not about how the children's "needs were not being met and how she could meet them," it was about her disapproval of the father's girlfriend, which led her to file for custody modification. So she failed to prove that a change was in the children's best interests. A guardian ad litem reported that the children were stable with no changes in their circumstances.