Hatton v. Hazelwood

GEORGE W. DRAPER III, Judge.

Vance T. Hazelwood (hereinafter, “Father”) appeals the denial of his motion to modify custody and support. Father claims that the trial court erred in failing to sua sponte appoint a guardian ad litem (hereinafter, “GAL”) for the minor child. We dismiss.

In a modification proceeding, the trial court determines whether a substantial change has occurred in the circumstances of the child or of the child’s custodian based on facts that have arisen since the prior decree. K.O.H. ex rel. Bax v. Huhn, 69 S.W.3d 142, 145 (Mo.App. E.D.2002). The court must then consider…