Mulford v. Sullivan

The mother appeals from an order modifying the final judgment of dissolution, transferring the custody of the parties’ youngest child from the mother to the father. She contends the fact that she has changed residences, the parties have experienced visitation difficulties, and both parties have remarried does not generally constitute a change of circumstances sufficient to justify a change in custody. We agree. McIntyre v. McIntyre, 452 So.2d 14 (Fla. 1st DCA 1984); Zediker v. Zediker, 444 So.2d 1034 (Fla. 1st DCA 1984); Tallent v. Tallent, 440 So.2d 623 (Fla. 2d DCA 1983); Robinson v.…