Graichen v. Graichen

There are two issues on this appeal: (1) Whether the record will sustain a finding of a substantial change in circumstances since the original adjudication of custody, and (2) whether oral examination of the minor child, Gay Graichen, in chambers by the court, constitutes prejudicial error where such interview, though not objected to by counsel for plaintiff, was made a part of the record.

The general rule in change-of-custody cases is that a substantial change in circumstances must be established in order to warrant a change in the custody of children. State ex rel. Hannon v. Eisler (1955),…