Graham R. v. Jane S.

Summary

The Alaska Supreme Court affirmed the modification of custody from Graham to Jane. It held that neither res judicata nor collateral estoppel barred Jane's modification motion because the prior protective-order proceeding did not litigate or decide custody or domestic violence. The court further held that Graham's substantial interference with Jane's visitation established changed circumstances and that the superior court did not abuse its discretion in finding modification to be in the child's best interests; any evidentiary errors were harmless.