Lyon v. Lyon

Feotón, Justice.

In this action brought by the father of a minor child against his former wife to obtain custody of the child, the applicant had the burden of showing that the former wife, to whom custody was originally awarded, is no longer able or suited to retain custody or that the conditions and circumstances surrounding the child have so changed that the welfare of the child would be enhanced by modifying the original judgment. Bowen v. Bowen, 223 Ga. 800 (2) (158 SE2d 233); Beckman v. Beckman, 225 Ga. 693, 694 (171 SE2d 135). “In determining whether or not a material change in…