Strickland v. Gay

Appellant, Wayne Strickland, appeals an order changing the primary residence of the parties’ child. Upon a careful review of the entire record, we find that there was no competent substantial evidence to support the trial court’s finding of a substantial or material change in circumstances since the entry of the last custody order.1 Thus, Appellee failed to satisfy her extraordinary burden, and the trial court abused its discretion in modifying the most recent custody order. See, e.g., Young v. Young, 732 So.2d 1133 (Fla. 1st DCA 1999); Kilgore v. Kilgore, 729 So.2d 402 (Fla. 1st DCA 1999);…