Hammac v. Hammac

I concur in affirming the denial of the change of custody because of the findings made by the trial judge and because much of the mother’s conduct which was the subject of this hearing may also have been occurring prior to the initial custody determination. I write because of my concern that in previous cases we may have sent the wrong message to trial judges. The correct message is that the burden of proof in modification of custody cases is difficult but not insurmountable. Young v. Young, 732 So.2d 1133 (Fla. 1st DCA 1999). Issues such as promoting family stability and deterring endless…