In re the Marriage of Zigler

¶1 Atrial judge who modifies a parenting plan must find, among other things, that a substantial change in circumstances makes the child’s primary residence detrimental to his health. RCW 26.09.260(2)(c). The finding must be based on facts that have arisen since the last contested parenting plan. RCW 26.09.260(1). Here, the trial judge modified a child’s primary residence from his mother’s house to his father’s house after finding that domestic violence at his mother’s house is detrimental to his health. This finding is based on acts of domestic violence between members of the mother’s…