Gardels v. Bowling
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The Supreme Court affirmed the judgment of the district court granting Father's petition to modify a child custody order granting Mother primary custody of the parties' daughter (Child), holding that there was no abuse of discretion during the proceedings below.
The original child custody order granted Mother primary custody of Child. Father later petitioned the court to modify the order, claiming that the original order had proved unworkable due to ambiguity in its terms. After a trial, the district court concluded that a material change of circumstances had occurred since the original order and that it was in Child's best interests for the parties to have shared custody. The Supreme Court affirmed, holding that there was no abuse of discretion in the district court's conclusion that there had been a material change of circumstances affecting Child's welfare since the original custody and visitation order and that Child's best interests would be served by granting the parties shared custody.
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