Margaret E. Nalley v. Michael Adams

Summary

The Supreme Court of Arkansas affirmed the circuit court's order requiring the parents to share equal parenting time and vacated the court of appeals' contrary decision. The court held that the father's relocation eliminated the geographic obstacle underlying the original unequal schedule and that the circuit court was enforcing its existing joint-custody order rather than modifying custody. Because no actual change of custody was sought, the material-change-in-circumstances analysis was not triggered.