J. M. v. S. C.

Summary

The Alaska Supreme Court affirmed the modification of custody that kept the child in Alaska with the father rather than relocating him to New Jersey with the mother. It held that the child’s substantial deterioration in emotional and behavioral functioning since the custody agreement justified reconsideration, and that the superior court’s best-interests analysis was neither clearly erroneous nor an abuse of discretion. The court also held that any error in admitting the parenting coordinator’s reports was harmless because the same conclusions were supported by substantial independent evidence.