James R. v. Kylie R.
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Two parents shared joint custody of their child during the pendency of their divorce, but the father's plans to move out of state led both parents to seek primary physical custody of the child. The superior court granted primary physical custody to the mother, concluding that all of the statutory factors but one were neutral between the parents but that the mother was more likely than the father to facilitate a close and continuing relationship between the other parent and the child. The father then appealed, arguing that the superior court erred: (1) by failing to find that the father had superior capability to meet the child's needs; and (2) by prompting the father to discuss his concerns about the mother's parenting and then holding those concerns against the father in the continuing-relationship determination. Finding no abuse of the trial court's discretion, the Supreme Court affirmed that court's determinations in all respects.
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