4 canonical passages across 3 cases, quoted by 36 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Visikides v. Derr.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Visikides v. Derr Anchor | green | “whether a change of circumstances exists is a factual finding that will not be disturbed on appeal if the finding is supported by credible evidence.” | 16 |
| 2 | Keel v. Keel | green | “first, has there been a change in circumstances since the most recent custody award; second, would a change in custody be in the best interests of the children.” | 8 |
| 3 | Keel v. Keel | green | “the test for modifying custody . . . has two prongs: first, has there been a change in circumstances since the most recent custody award; second, would a change in custody be in the best interests of the children.” | 7 |
| 4 | Hughes v. Gentry | green | “the parent seeking to obtain a transfer of custody bears the burden to show a change in circumstances following the most recent custody award.” | 5 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.