In re Marriage of Zuidema

I would affirm the decision of the trial court in this case and, therefore, I must dissent from the opinion filed by the majority.

In reversing the custody order of the circuit court of Whiteside County, the majority does not find that the wrong legal standard was applied or that the decision to change custody was in any way erroneous. Instead, a new standard of review has apparently been adopted: when the basis for the action of the trial court is “unclear” it will be reversed. I prefer to adhere to the traditional rules that the trial court will be affirmed unless error is clearly…