Rosemary Hutchison, Plaintiff and Appellant v. Dale Harry Hutchison, Defendant and Respondent

Summary

The Utah Supreme Court vacated the district court’s order granting permanent custody of the children to the non‑parent father and remanded for further proceedings. It held that the trial court must make explicit findings of fact and conclusions of law concerning the parental presumption and the best‑interest factors before awarding custody. The decision clarifies the rebuttable presumption in favor of a natural parent and the standards for appellate review of custody determinations.