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Recent Posts in Child Custody Category

Case law update: Best interest factors discussed

Best Interest Factors Discussed Statute makes child’s best interest the circuit court’s central objective and rule bars new trial on any error that does not materially affect that outcome. ...
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Missouri relcoation statute

Missouri law governs the relocation of children after a custody order has been entered. "Relocation" is defined as "a change in the principal residence of a child for a period of ninety ...
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Child's conduct toward parent irrelevant in child support payments

Trial Court erred in failing to follow two-step procedure for determining child support. Child's SSI from Father's disability does not constitute income to Father or credit for Mother. ...
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"Significant" visitation precludes "sole" physical custody

Recent ruling: TC A Minor Child, by and through JC, Next Friend and JC, Individually v SI Missouri Court of Appeals, Western District - WD7455 Father appeals from a judgment entered in the Circuit ...
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Caselaw update: child's name change within trial court's discretion

Recent Case: M.R.H., Respondent, vs. J.N.P., Appellant. Missouri Court of Appeals, Eastern District - ED97338 More common in paternity actions than divorce actions, the issue of what surname the child ...
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Genetic tests mught be insufficient standing alone

Identical twins yield identical paternity tests. State of Missouri, ex rel., Department of Social Services, Division of Child Support Enforcement, and Holly Marie Adams, Petitioners/Respondents v. ...
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SRS lacks standing to appeal Child in Need of Care cases when it is not a party to the action

In order to appeal a case brought under the Revised Kansas Code for Care of Children, K.S.A. 2010 Supp. 38-2201 et seq., one must be a party or an interested party in the case. In addition, only ...
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Case law update: Court must hold evidentiary hearing for change of custody

In a recent case, the Kansas Court of Appeals held that a district court must hold an evidentiary hearing before reyling on case managers' recommendations for child custody when those ...
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Awarding Tax Exemption to Non-Custodial parent

CB v. DB Missouri Court of Appeals, Southern District - SD31614 Notwithstanding the fact that the Missouri case law generally states that tax benefits must go to the custodial spouse unless the trial ...
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Strict Compliance with Relocation Notification Statute

Under § 452.377, RSMo, relocation of child’s residence requires strict compliance to statutorily required notice before strict compliance with time to file objection to relocation is ...
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Factors to Weigh in Custody Disputes

Under Missouri law, the parties' intent regarding parenting plans in a divorce or other custody case will be given great weight in most circumstances. As a practical matter, the courts will almost ...
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20% Child Support modification rule doesn't apply without change of circumstaces

Ordinarily, Missouri child support is subject to revision when financial circumstances change such that the child support amount by 20% or more. However, there must be an actual material change in ...
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Child Support not subject to collateral attack; Court of Appeals can amend child support based on judicial admission

Recent Case: TLD v. JRD Missouri Court of Appeals, Western District - WD73385 Mother appeals from the trial court's amended judgment order of modification retroactively modifying Father’s ...
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Awarding Tax Dependencey Credit to non-custodial spouse: No income shown

New Case Law: CB v. DB Missouri Court of Appeals, Southern District - SD31614 Notwithstanding the fact that the Missouri case law generally states that tax benefits must go to the custodial spouse ...
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Missouri relocation statute requires strict compliance with notice

Under § 452.377, RSMo, relocation of child’s residence requires strict compliance to statutorily required notice before strict compliance with time to file objection to relocation is ...
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No contempt found without intentional and contumacious conduct

The Circuit court ordered re-financing of the house after divorce. At the hearing on a subsequent contempt action, the circuit court found that failure to comply was not contemptuous because party did ...
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No Child Abandonment without Knowledge of Birth

Recent Ruling: Termination of parental rights requires proof of statutory grounds by clear, convincing and cogent evidence, and proof of child’s best interest by a preponderance of the evidence. ...
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Delegation of Parenting decisions to third parties held unenforceable

In a ruling by the Missouri Court of Appeals, in a custody modification proceeding, the trial court’s modified parenting plan delegated the authority to make all medical, educational, and ...
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Court lacked personal jurisdiction to order child support

Most states, like Kansas, have enacted a version of the Uniform Child Custody Jurisdiction Enforcement Act (UCCJEA). A few, like Missouri, still have the predecessor act, the UCCJA, which operates ...
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