Shayla Williams, F/k/a Shayla Barbee, Appellant v. Jomell Barbee, Appellee

Summary

The Alaska Supreme Court reversed the custody award granting Barbee primary physical and shared legal custody if Williams relocated. It held that the statutory presumption against custody for a parent with a history of domestic violence applies in custody-modification proceedings, and that the superior court plainly erred by failing to make express findings about whether Barbee's conduct met that statutory definition. The court also held that the superior court had to inquire into Williams's additional allegations and allow her to present supporting evidence before deciding whether a history existed.