LaFlam v. LaFlam
Annotate this CaseMother Diana LaFlam appealed the denial of her motion to modify physical and legal rights and responsibilities. She argued that her relocation to Florida following a divorce from father Jody LaFlam was an unanticipated circumstance requiring modification of the physical rights and responsibilities of their two children, and that father’s neglect of the children’s health warranted a modification of legal rights and responsibilities. Father cross-appealed the portion of the order finding that his neglect of the children’s health constituted changed circumstances under 15 V.S.A. § 668(a). The Vermont Supreme Court agreed with the family division that mother’s relocation was not a change in circumstances as to physical rights and responsibilities, and that father’s conduct was a change in circumstances with respect to legal rights and responsibilities. The Court reversed and remanded as to the trial court's best-interests analysis.
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