Michel test (Missouri) · Go Syfert
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Michel test in Missouri

7 Missouri opinions name it 1 courts 2001–2011 0 in the last five years

The cases below were cited by Missouri 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 (3)

CaseFollowedCited
Stowe v. Spencegreen
mo · 2001 · cited in 5 Missouri opinions naming this issue, 2001–2011
2 sentences

2011In 2001, the Missouri Supreme Court declared in Stowe that the four-part Michel test is no longer to be applied. 41 S.W.3d at 469-70 .

2011In 2001, the Missouri Supreme Court declared in Stowe that the four-part Michel test is no longer to be applied. 41 S.W.3d at 469-70 .

15
Abernathy v. Meiergreen
moctapp · 2001 · cited in 4 Missouri opinions naming this issue, 2001–2003
2 sentences

2003In Abernathy v. Meier, 45 S.W.3d 917 (Mo.App.2001), the court explained the differences between the Michel test and the relocation test set forth in the present version of § 452.377: There are three essential differences between the standard announced in sections 9 and 10 of § 452.377 and the four-part Michel test.

2003In Abernathy v. Meier, 45 S.W.3d 917 (Mo.App.2001), the court explained the differences between the Michel test and the relocation test set forth in the present version of § 452.377: There are three essential differences between the standard announced in sections 9 and 10 of § 452.377 and the four-part Michel test.

14
Green v. Greengreen
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2001–2001
2 sentences

2001See e.g., Green v. Green, 26 S.W.3d 325, 328 (Mo.App.2000).

2001See e.g., Green v. Green, 26 S.W.3d 325, 328 (Mo.App.2000).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Sadler v. Favro green
moctapp · 2000
2 sentences

2003In Sadler , this court, although recognizing that § 452.377.9 expressly provided that the relocating parent had the burden of proving that the proposed relocation was made in good faith and was in the children’s best interests, nonetheless held that the four factors of the Michel test were “important to determining the propriety of the relocation.” Sadler, 23 S.W.3d at 258 .

2003In Sadler , this court, although recognizing that § 452.377.9 expressly provided that the relocating parent had the burden of proving that the proposed relocation was made in good faith and was in the children’s best interests, nonetheless held that the four factors of the Michel test were “important to determining the propriety of the relocation.” Sadler, 23 S.W.3d at 258 .

12003–2003
Boling v. Dixon green
moctapp · 2000
2 sentences

2003Boling relied, in part, on Sadler, Boling, 29 S.W.3d at 388 , and Seaman relied, in part, on Boling, Seaman, 41 S.W.3d at 894 , for the same proposition.

2003Boling relied, in part, on Sadler, Boling, 29 S.W.3d at 388 , and Seaman relied, in part, on Boling, Seaman, 41 S.W.3d at 894 , for the same proposition.

12003–2003
Seaman v. Seaman green
moctapp · 2001
2 sentences

2003Boling relied, in part, on Sadler, Boling, 29 S.W.3d at 388 , and Seaman relied, in part, on Boling, Seaman, 41 S.W.3d at 894 , for the same proposition.

2003Boling relied, in part, on Sadler, Boling, 29 S.W.3d at 388 , and Seaman relied, in part, on Boling, Seaman, 41 S.W.3d at 894 , for the same proposition.

12003–2003
Michel v. Michel green
moctapp · 1992
2 sentences

2001Rather than looking to the “general quality of life for the custodial parent and child” (Michel, 834 S.W.2d at 777 ), section 9 requires the court to determine only that the relocation is in the best interests of the child. § 452.377.9.

2001Rather than looking to the “general quality of life for the custodial parent and child” (Michel, 834 S.W.2d at 777 ), section 9 requires the court to determine only that the relocation is in the best interests of the child. § 452.377.9.

12001–2001
Brethorst v. Brethorst green
moctapp · 2001
2 sentences

2001Id. *114 In its judgment issued four months before the Stowe decision, the trial court made specific findings with reference to the four Michel factors.

2001Id. *114 In its judgment issued four months before the Stowe decision, the trial court made specific findings with reference to the four Michel factors.

12001–2001

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 452.377 (7) MO § Mo. Rev. Stat. § 452.375 (4) MO § Mo. Rev. Stat. § 452.410 (3)

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

MO 7 (2001–2011) NY 2 (2014–2014)

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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