Gurney v. Gurney

GOLDEN, Chief Justice.

In this appeal, the primary issue we consider is whether it is necessary to demonstrate a substantial change in circumstances in order to modify an order of joint custody when both parents inform the district court that the joint custody arrangement has failed. Appellant Renae G. Gurney, now known as Renae G. Tollman (Renae), and appellee Russell C. Gurney (Russell) shared custody of their daughter (Laurie) following their divorce in July of 1993. Within fifty days after the divorce decree was filed, Russell petitioned for primary custody of the child. Following a…