Lamb v. Wenning

SHEPARD, Chief Justice.

What standard applies to a request for a change in primary physical custody when divorced parents have joint legal custody of their child? We hold that a petition for change can be granted only upon "a showing of changed circumstances so substantial and continuous as to make the existing order unreasonable."

Case History

As part of an agreement to settle on the dissolution of their marriage, Robin and Larry Wenning agreed that they would share joint legal custody of their son Jerry (then age six), that Robin would have primary physical custody, and that Larry would pay…