COA Examines Need for Evidentiary Hearing in Child Threshold Case
In D’itri v Bollinger, the mother of the child filed a motion to change custody claiming there was a change in circumstances in the child’s living situation.
Third Party Custody Decisions Sets the Trial Court Straight
The Court of Appeals in Frowner v Smith, addressed whether a parent has to satisfy the Vodvarka threshold to change custody from a third party custodian.