Gochenaur v. Gochenaur

One issue is dispositive of this appeal: Is a mother, who has never been declared unfit but who has stipulated to the custody of her three children being with the father at a hearing immediately preceding a temporary order placing custody of the children with the father, and who is subsequently adjudged the “guilty party” in the divorce action at which she did not appear and at which legal custody was granted to the father of those three children even though she had physical custody of two of the children, required to show a change of conditions at a hearing on her subsequent petition to…