Keel test (Virginia) · Go Syfert
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Keel test in Virginia

8 Virginia opinions name it 1 courts 1988–2026 3 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Hiner v. Hadeedgreen
vactapp · 1993 · cited in 2 Virginia opinions naming this issue, 1998–1998
2 sentences

1998See Hiner v. Hadeed, 15 - 4 - Va. App. 575, 580, 425 S.E.2d 811, 814 (1993).

1998See Hiner v. Hadeed, 15 - 4 - Va. App. 575, 580, 425 S.E.2d 811, 814 (1993).

22
Keel v. Keelgreen
va · 1983 · cited in 3 Virginia opinions naming this issue, 1988–2021
2 sentences

2021See id.; Keel, 225 Va. at 611-12 .

2021See id.; Keel, 225 Va. at 611-12 .

13
Wheeler v. Wheelergreen
vactapp · 2004 · cited in 1 Virginia opinions naming this issue, 2021–2021
2 sentences

2021See Wheeler v. Wheeler, 42 Va. App. 282, 289 (2004); see also Hughes, 18 Va. App. at 322 (noting that the threshold requirement for materially changed circumstances “provide[s] stability in the life of the child whose custody is the subject of the conflict between the parents”).

2021See Wheeler v. Wheeler, 42 Va. App. 282, 289 (2004); see also Hughes, 18 Va. App. at 322 (noting that the threshold requirement for materially changed circumstances “provide[s] stability in the life of the child whose custody is the subject of the conflict between the parents”).

11
Hughes v. Gentrygreen
vactapp · 1994 · cited in 1 Virginia opinions naming this issue, 2021–2021
2 sentences

2021See Wheeler v. Wheeler, 42 Va. App. 282, 289 (2004); see also Hughes, 18 Va. App. at 322 (noting that the threshold requirement for materially changed circumstances “provide[s] stability in the life of the child whose custody is the subject of the conflict between the parents”).

2021See Wheeler v. Wheeler, 42 Va. App. 282, 289 (2004); see also Hughes, 18 Va. App. at 322 (noting that the threshold requirement for materially changed circumstances “provide[s] stability in the life of the child whose custody is the subject of the conflict between the parents”).

11
Turner v. Turnergreen
vactapp · 1986 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008See also Turner v. Turner, 3 Va. App. 31, 35 , 348 S.E.2d 21, 23 (1986) (first prong of Keel test met where noncustodial parent showed remarriage has stabilized, child had undergone changes and had expressed a preference in living with the noncustodial parent). 4 Indeed, father conceded in his testimony that the schedule was no longer workable, and his counsel argued: There is no doubt that there has been a material change of circumstance since the final decree was entered back in December -5- We find that the evidence in this case supports the court’s ruling that a change of circumstances occ

2008See also Turner v. Turner, 3 Va. App. 31, 35 , 348 S.E.2d 21, 23 (1986) (first prong of Keel test met where noncustodial parent showed remarriage has stabilized, child had undergone changes and had expressed a preference in living with the noncustodial parent). 4 Indeed, father conceded in his testimony that the schedule was no longer workable, and his counsel argued: There is no doubt that there has been a material change of circumstance since the final decree was entered back in December -5- We find that the evidence in this case supports the court’s ruling that a change of circumstances occ

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Klein v. Klein green
vactapp · 2007
2 sentences

2026To determine whether father’s evidence met the “particular standard,” Klein, 49 Va. App. at 481 , the circuit court was required to make factual determinations as to whether father established a material change in circumstance.

2026To determine whether father’s evidence met the “particular standard,” Klein, 49 Va. App. at 481 , the circuit court was required to make factual determinations as to whether father established a material change in circumstance.

12026–2026

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (5) VA § Va. Code Ann. § 20-124.3 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

VA 8 (1988–2026) FL 2 (1996–1999)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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