Dobson v. Dobson

Tammy Sue Dobson (“mother”) appeals an order modifying custody, contending that the father, Jerry Eugene Dobson (“father”), failed to prove that a substantial change in circumstances occurred, or that a custody change would be in the children’s best interest. We disagree and affirm.

A modification of custody is permitted when a material change in circumstances has occurred and a change of primary residential custody is in the best interest of the children. See Stearns v. Szikney, 386 So.2d 592, 594 (Fla. 5th DCA 1980) (citing Sanders v. Sanders, 376 So.2d 880 (Fla. 1st DCA 1979)).

The record,…