In RE MARRIAGE OF ABEL v. Johnson

Leslie L. Johnson (Leslie) appeals the post-judgment orders of the family court modifying a divorce judgment to award child support to his former wife, Linda L. Abel (Linda) and refusing to vacate a previous order transferring physical custody of the parties’ minor child, Robert, from Leslie to Linda. The principal issue on appeal is whether that portion of sec. 767.32(2), Stats., governing modification of custody orders, commonly referred to as the “Millikin standard” (Millikin v. Millikin, 115 Wis. 2d 16, 339 N.W.2d 573 (1983)), applies to transfers of physical placement under a joint…