Problem:
In Santosky v. Kramer (1982) the Supreme Court - . held that the care, custody, and management of children is a not a natural parent's fundamental liberty protected by the due process clause. . held that the care, custody, and management of children is a natural parent's fundamental liberty and the government must prove by "substantial evidence" that terminating custody is necessary to achieve a compelling goal. . held that the care, custody, and management of children is a natural parent's fundamental liberty and the government must prove by "clear and convincing evidence" that terminating custody is necessary to achieve a compelling goal. . held that the care, custody, and management of children is a natural parent's fundamental liberty and the government must prove by "beyond a reasonable doubt" that terminating custody is necessary to achieve a compelling goal.