W.T.M. v. S.P.

The lead opinion in the second appeal of this case, W.T.M. v. S.P., 802 So.2d 1091 (Ala.Civ.App.2001) (“W.T.M.IIconclud-ed that the judgment of the trial court was the result of a dispositional hearing in a dependency proceeding, not a change of custody under Ex parte McLendon, 455 So.2d 863 (Ala.1984). It therefore reasoned that the “material-promotion” standard of McLendon did not apply and that, as a result, the case should be remanded for the trial court to determine custody upon application of a “best-interests” standard. After reviewing the record and the trial court’s judgment on…