Ianelli v. Camino
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The Supreme Court reversed the judgment of the district court granting Father's petition to modify custody and awarding Father primary physical custody of the parties' four-year-old son, holding that the district court abused its discretion when it ignored certain material factors in determining that modification of the original order was warranted.
After a trial, the district court found that Mother's move from Buffalo, Wyoming to Plains, Montana constituted a material change in circumstances and that it was in the child's best interests to grant Father primary physical custody. The Supreme Court reversed, holding (1) the district court did not abuse its discretion determining that a material change in circumstances justified reopening its prior custody order; but (2) the district court abused its discretion when it determined that transferring custody to Father was in the child's best interests.
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