Baker v. Baker

Jerome L. Baker (“Former Husband”) appeals the trial court’s postdissolution order transferring temporary “custody” of the parties’ minor children to Sabrina J. Gray (“Former Wife”) until further order of the court.1 Former Husband argues that the court erred in temporarily changing custody because Former Wife failed to plead and prove a substantial change in circumstances since the last custody determination and by modifying custody at a hearing that was not noticed for a modification proceeding. We agree and reverse.

*492The parties’ marriage was dissolved by a final judgment entered on…