Strong v. Strong

Defendant Irene Strong appeals an order that modified the parties’ divorce decree to increase the plaintiff Dennis Strong’s visitation rights with the parties’ children. We hold that the lower court erroneously failed to make a finding on a critical issue, and therefore reverse and remand for a new hearing.

The parties were married in 1972, and had one child. In addition, Mr. Strong adopted Mrs. Strong’s two children from a previous marriage. Mr. Strong also had custody of an older child from a prior marriage.

The parties were divorced in 1981. Mrs. Strong was given custody of the three…