Hirsch v. Hirsch

I join the majority in affirming the trial court. However, I cannot join the majority’s expression of the law governing changes of custody. In recent years, beginning with Hogge v. Hogge, 649 P.2d 51 (Utah 1982), we have struggled to articulate standards that must be met before changes of custody can be ordered. The resulting case law makes it clear that custody changes are the exception and that they are governed by strict standards that are different from those by which initial custody awards are made.1 The majority opinion acknowledges this line of authority. But it does not analyze the…