Doyle v. Doyle
Annotate this CaseAfter a Robin Doyle and Doug Doyle obtained a litigated custody decree, Robin petitioned the trial court for a modification of the custody of her son, maintaining that there had been a substantial and material change in circumstances when Robin moved from Colorado back to the same neighborhood as her son. The court granted her petition, transferring custody from the child's father, Doug, to Robin. On appeal, the court of appeals affirmed in part and reversed and remanded for recalculation of child support. The Supreme Court affirmed the judgment of the trial court, holding (1) formal bifurcation of the changed circumstances and best interests proceedings was not required by Utah law and the trial court appropriately received evidence regarding changed circumstances and best interest; (2) the trial court correctly found a change in circumstances even when there was no change in the custodial parent's circumstances; and (3) the trial court had ample authority to modify the child support order in the absence of a specific request in Robin's petition for modification of custody.
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