Walsh v. Smith
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The Supreme Court affirmed the order of the district court modifying visitation and child support after Mother moved to Idaho, holding that the district court did not abuse its discretion.
After Mother moved to Idaho from Wyoming Father petitioned to modify custody, visitation and support, requesting physical and residential custody of the parties' daughter. Mother counterclaimed to maintain primary physical custody of the child. The district court then issued a final order concluding that Mother's move constituted a material change in circumstances and that it was in the child's best interest for Father to have primary physical and residential custody of the child. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it (1) determined that it was in the child's best interest for Father to have primary physical and residential custody of the child after she enters kindergarten; and (2) established the visitation plan.
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