Resolving where the children of O.J. Simpson should live is likely to depend on a two-part legal test that the court would follow, says a UC Davis law scholar who specializes in contested adoption and custody cases in which children's rights have been ignored. For the children to remain with their grandparents, the Browns, against Simpson's wishes, they would have to show that it would be detrimental for the children to return to Simpson and that the best interests of the children require that they remain with the Browns, says Joan Hollinger, a visiting professor at the UC Davis law school. Typically, in California, the law gives biological parents a preference to maintain or regain custody of their children. But a 1994 state law now requires courts to consider any history of domestic abuse or violence in awarding custody or visitation, Hollinger says. In determining with whom the Simpson children should live, she says, "the court could take into account the effect Simpson's history of domestic violence would have on the children."