In Troxel v Granville, the Supreme Court invalidated a state law authorizing courts to award grandparents visitation, over parental objections, upon a finding that visitation is in the child's best interests. This Article argues that Troxel was rightly decided, but that the Court did not go far enough. Judicial review of visitation disputes under a child-welfare standard creates high litigation costs but yields little improvement in parental incentives. Thus, the common law rule, under which parents had plenary discretion over visitation issues, is clearly superior to most grandparent visitation laws. The Troxel ruling, that courts may review visitation disputes provided they give some deference to parental judgments, will reduce the damage done by these laws. But had the Court's tacit intermediate-scrutiny review been better informed by economic analysis, it would have opted for a stronger rule forbidding any judicial review of parental visitation decisions in most circumstances.