Richardson v. Davis-Reed

Summary

The Supreme Court of Delaware affirmed the Family Court’s denial of the father’s petition to modify the children’s primary residential placement. Because the petition was filed within two years of a prior order entered after a full hearing, modification required a finding that continued enforcement could endanger the children’s physical health or significantly impair their emotional development, which the Family Court did not make. The Court deferred to the Family Court’s credibility determinations and declined to consider challenges to the earlier custody order. No separate opinions were filed.