"Material Change in Circumstances" Still a Substantial Burden
Custodial parent called his son a "problem child" to his face; told him that retaining an attorney cost him $1,000; called the child derogatory names during periods of anger; became less flexible on visitation after non-custodial parent filed for a change of custody; the child does not get along well with his new step-mother; and the child wants to have custody changed. Custody changed by the court? Nope. Arkansas Court of Appeals decided that these factors do not amount to a change in circumstances sufficient to change custody.