6 Alaska opinions name it 1 courts 1990–2024 2 in the last five years
The cases below were cited by Alaska 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.
| Case | Followed | Cited |
|---|---|---|
Abby D. v. Sue Y.green2 sentences2021Jay concedes the videos were made in the 21 And the girl is currently in Jay’s custody and “seeing excellent counselors.” 22 Abby D., 378 P.3d at 391 (quoting Bagby v. Bagby, 250 P.3d 1127, 1128 (Alaska 2011)). -10- 1816 summer of 2018, before the custody modification hearing that granted him primary physical custody. 2019See Abby D. v. Sue Y., 378 P.3d 388, 394 (Alaska 2016) (“A motion to modify custody triggers a right to an evidentiary hearing only if the moving party ‘make[s] a prima facie showing of a substantial change in circumstances affecting the child[]’s welfare.’ ” (alterations in original) (quoting Hope P. v. Flynn G., 355 P.3d 559, 565 (Alaska 2015))). -4- 1721 | 1 | 2 |
Pingree v. Cossettegreen1 sentence2024It told the parties Eli’s safety around Connor was “the biggest issue” at the custody modification hearing and eventually concluded its order modifying visitation by stating, “Given the safety concerns in Cory’s home, it is in [Eli]’s best interest that the Court modify Cory’s visits . . . .” The court’s finding that Connor had not received any appropriate treatment immediately followed a statement about the “future risk of harm” that Connor presents to Eli, suggesting that 13 See Sandberg v. Sandberg, 322 P.3d 879, 889 (Alaska 2014). 14 Pingree v. Cossette, 424 P.3d 371, 377 (Alaska 2018) (“C | 1 | 1 |
Vachon v. Pugliesegreen1 sentence2024It told the parties Eli’s safety around Connor was “the biggest issue” at the custody modification hearing and eventually concluded its order modifying visitation by stating, “Given the safety concerns in Cory’s home, it is in [Eli]’s best interest that the Court modify Cory’s visits . . . .” The court’s finding that Connor had not received any appropriate treatment immediately followed a statement about the “future risk of harm” that Connor presents to Eli, suggesting that 13 See Sandberg v. Sandberg, 322 P.3d 879, 889 (Alaska 2014). 14 Pingree v. Cossette, 424 P.3d 371, 377 (Alaska 2018) (“C | 1 | 1 |
Sandberg v. Sandberggreen1 sentence2024It told the parties Eli’s safety around Connor was “the biggest issue” at the custody modification hearing and eventually concluded its order modifying visitation by stating, “Given the safety concerns in Cory’s home, it is in [Eli]’s best interest that the Court modify Cory’s visits . . . .” The court’s finding that Connor had not received any appropriate treatment immediately followed a statement about the “future risk of harm” that Connor presents to Eli, suggesting that 13 See Sandberg v. Sandberg, 322 P.3d 879, 889 (Alaska 2014). 14 Pingree v. Cossette, 424 P.3d 371, 377 (Alaska 2018) (“C | 1 | 1 |
Bagby v. Bagbygreen1 sentence2021Jay concedes the videos were made in the 21 And the girl is currently in Jay’s custody and “seeing excellent counselors.” 22 Abby D., 378 P.3d at 391 (quoting Bagby v. Bagby, 250 P.3d 1127, 1128 (Alaska 2011)). -10- 1816 summer of 2018, before the custody modification hearing that granted him primary physical custody. | 1 | 1 |
Hope P. v. Flynn G.green1 sentence2019See Abby D. v. Sue Y., 378 P.3d 388, 394 (Alaska 2016) (“A motion to modify custody triggers a right to an evidentiary hearing only if the moving party ‘make[s] a prima facie showing of a substantial change in circumstances affecting the child[]’s welfare.’ ” (alterations in original) (quoting Hope P. v. Flynn G., 355 P.3d 559, 565 (Alaska 2015))). -4- 1721 | 1 | 1 |
Cushing v. Paintergreen2 sentences2013In Cushing v. Painter9 we found that the trial court violated a parent’s right to due process by entering a permanent child custody order when notice of the scheduled hearing stated it would concern only 7 Alaska Const. art. 1 § 7; Siekawitch v. Siekawitch, 956 P.2d 447, 449 (Alaska 1998). 8 Cushing v. Painter, 666 P.2d 1044, 1046 (Alaska 1983). 9 666 P.2d 1044 (Alaska 1983). -7- 1452 interim custody and the parties had only five days to prepare.10 The custody modification hearing in Cushing was initially characterized as an interim hearing, limited to the question of where the child would res 2013In Cushing v. Painter9 we found that the trial court violated a parent’s right to due process by entering a permanent child custody order when notice of the scheduled hearing stated it would concern only 7 Alaska Const. art. 1 § 7; Siekawitch v. Siekawitch, 956 P.2d 447, 449 (Alaska 1998). 8 Cushing v. Painter, 666 P.2d 1044, 1046 (Alaska 1983). 9 666 P.2d 1044 (Alaska 1983). -7- 1452 interim custody and the parties had only five days to prepare.10 The custody modification hearing in Cushing was initially characterized as an interim hearing, limited to the question of where the child would res | 1 | 1 |
Siekawitch v. Siekawitchgreen1 sentence2013In Cushing v. Painter9 we found that the trial court violated a parent’s right to due process by entering a permanent child custody order when notice of the scheduled hearing stated it would concern only 7 Alaska Const. art. 1 § 7; Siekawitch v. Siekawitch, 956 P.2d 447, 449 (Alaska 1998). 8 Cushing v. Painter, 666 P.2d 1044, 1046 (Alaska 1983). 9 666 P.2d 1044 (Alaska 1983). -7- 1452 interim custody and the parties had only five days to prepare.10 The custody modification hearing in Cushing was initially characterized as an interim hearing, limited to the question of where the child would res | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Alaska. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Ronny M. v. Nanette H.
green
1 sentence2015Given that Chris’s substance abuse issues began before the parties even separated, it is impossible to determine whether the superior court abused its discretion in concluding that Chris’s struggles warranted custody modification with respect to Anna. 11 See Ronny M., 303 P.3d at 402 (quoting Chesser, 178 P.3d at 1158 ) (internal quotation marks omitted). -6- 1531 The court also referenced concerns about Anna’s academic performance, which were discussed at the original custody modification hearing in February 2013. | 1 | 2015–2015 |
Chesser v. Chesser-Witmer
green
1 sentence2015Given that Chris’s substance abuse issues began before the parties even separated, it is impossible to determine whether the superior court abused its discretion in concluding that Chris’s struggles warranted custody modification with respect to Anna. 11 See Ronny M., 303 P.3d at 402 (quoting Chesser, 178 P.3d at 1158 ) (internal quotation marks omitted). -6- 1531 The court also referenced concerns about Anna’s academic performance, which were discussed at the original custody modification hearing in February 2013. | 1 | 2015–2015 |
House v. House
green
2 sentences1990Citing House, 779 P.2d 1204 , the dissent implies that the move, having served its role as prima facie proof of "changed circumstances," is no longer an essential part of the custody modification analysis. 1990Citing House, 779 P.2d 1204 , the dissent implies that the move, having served its role as prima facie proof of “changed circumstances," is no longer an essential part of the custody modification analysis. | 1 | 1990–1990 |
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.