McDonald v. McDonald

The father appeals from an order granting a change of custody to the mother.

The divorce was awarded upon the mother’s counterclaim in July, 1972, and the decree awarded custody of Shawn, then aged four and one-half years old, to the father, and of Ryan, then aged two years eight months old, to the mother. The decree does not show that any evidence was heard upon the issue of custody and there is no finding of fact by the court or determination concerning the best interests of the children. Such placing of the children had been arranged by the parents at the time of the separation in 1970,…