Frequent moves support change in primary residence - Published opinion from Ky Court of Appeals

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Trial court granted Father primary custody after a hearing. The trial court made findings including that mother moved frequently causing the child to change schools four times in one academic year. Mother appealed arguing the trial court “ improperly considered her personal life” and failed to make the factual findings required by KRS 403.270(2). The Court of Appeals disagreed noting “Mother failed to request specific findings pursuant to CR 52.04” and holding that there was “more than sufficient evidence” to support the trial court’s findings.

Digested by Elizabeth M. Howell

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