Anderson v. JohnsonAnnotate this Case
After Suzanne Anderson and Joseph Johnson divorced, the family court entered an order awarding joint custody of their daughter which stated that timesharing would be on an equal time basis. Anderson subsequently filed a motion to modify the timesharing schedule to allow her to move with the child to Kentucky. The family court denied the motion, determining that it was not in the child's best interests to relocate. Anderson appealed, asking that the case be remanded for specific findings of fact. The court of appeals affirmed, holding that findings of fact are not necessary when the court denies a modification motion. The Supreme Court reversed, holding that the trial court's order, which included no findings of fact to support its conclusion, violated Ky. R. Civ. P. 52.01. Remanded to the family court to make specific findings of fact and separate conclusions of law.