Opinion No. 79-213a (1980) Ag Disposition : See: Opinion No. 79-213a (1979)

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that short-term changes in mother’s life did not show substantial change necessary to modify custody
• holding that mother’s mental health assessment, four months of sobriety, new spouse, and new job were short-term changes that did not constitute materially changed circumstances for purposes of custody modification
• explaining that violation of custody (continued...
• “[I]t would be antithetical to the child’s best interests to apply [the parental preference presumption] again in [custody] modification proceedings.”
• “[W]hen [a] non-parent has already been granted permanent custody, the parental preference drops out in subsequent modification proceedings.” (quoting Evans v. McTaggart, 88 P.3d 1078, 1085 n.32 (Alaska 2004))
• “A motion to modify custody triggers a right to an evidentiary hearing only if the moving party ‘make[s] a prima facie showing of a substantial change in circumstances affecting the child[]’s welfare.’ ”

Source: CourtListener parenthetical corpus (CC0).