Graham R. v. Jane S.
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Graham R. and Jane S. had one child. A 2006 court order granted Graham sole legal and primary physical custody. In 2012 Graham traveled to California for heart surgery and took the child with him, cutting off contact with Jane and causing her to miss a number of scheduled visits. When Graham returned to Alaska Jane moved for sole legal and primary physical custody, and the superior court granted her motion after an evidentiary hearing. Graham appealed that order, arguing that it was barred by principles of res judicata and collateral estoppel; that the court erred in finding that his interference with Jane’s visitation rights was an act of domestic violence that constituted changed circumstances; and that the court erred in admitting evidence of his criminal convictions and of the child’s preferences. Upon review, the Supreme Court affirmed the superior court’s order modifying custody, concluding that there was no error in its decision not to apply res judicata or collateral estoppel; that there were changed circumstances justifying a modification of custody; and that any evidentiary errors were harmless.
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