Cooper v. Robertson

Modification of an existing custody arrangement is permissible only upon a showing that there has been a change in cir*744cumstances such that modification is necessary to ensure the best interests of the child (see Matter of Tobar v Velez-Molina, 95 AD3d 1224 [2012]). The court must consider the totality of the circumstances (id.). In this regard, the court should consider whether the alleged changed circumstances indicate that one of the parties is unfit, the nature and quality of the relationships between the child and the parties, and the existence of a prior agreement (id. at 1224-1225).…