Kehus v. Euteneier

(dissenting)—In Patterson v. Patterson (1957), 51 Wn. (2d) 162, 316 P. (2d) 902, the court reiterated and emphasized a policy of very strong reliance on trial court determinations in child custody matters. We said in Applegate v. Applegate (1959), 53 Wn. (2d) 635, 335 P. (2d) 595, that an award of child custody made by a trial court will be overturned only if there has been a manifest abuse of discretion. Very strong reliance is to be distinguished from absolute adherence, as evidenced by our reversal of the trial court in Thompson v. Thompson (1960), 56 Wn. (2d) 244, 352 P. (2d) 179.

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