Graham R., Appellant v. Jane S., Appellee

Summary

The Alaska Supreme Court affirmed the modification of custody from Graham to Jane after Graham took the child to California for medical treatment, withheld information about the child’s location, and caused Jane to miss multiple visits. The court held that the prior protective-order proceeding did not preclude the custody-modification motion because custody and domestic violence had not been actually litigated or decided there. It also held that Graham’s substantial interference with visitation constituted changed circumstances and that the superior court properly found modification to be in the child’s best interests; any evidentiary errors were harmless.