The Standards of Proof which a Court must consider in granting an Adoption without the Consent of a birth parent includes standard "catch all" language.
That is to say, that a Court may consider all rlevant evidence on the issue of the best interests of the child, and is not limited by the eight enumerated factors.
Therefore, attorneys may argue that other factors are important and should be considered by the Court.
It should be remembered, however, that the inquiry is wheter a required consent to a proposed adoption is withheld contrary to the best interests of the child, not what is in the best interests of the child generally. The Supreme Court of Virginia has been very specific and stating that an adoption is not a comparison of two homes and a decision which is the better home.
This is because adoption terminates birth parent rights, and those rights are protected under the 14th Amendment to the United States Consitution.