Wendy Grungo-Smith v. Joseph Grungo

Summary

The South Carolina Supreme Court reversed the Court of Appeals, holding that S.C. Code § 63‑3‑830(A)(6) does not require extraordinary circumstances for a family court to request a guardian ad litem’s custody recommendation, that the father established a substantial change in circumstances, and that awarding primary custody to the father serves the children’s best interests. The Court reinstated the family‑court order granting the father primary custody.