Missouri Revised Statutes

Mo. Rev. Stat. § 452.411 (2026)

Change of residence deemed grounds for modification of custody, when

✓ current as of May 2026

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452.411. Change of residence deemed grounds for modification of custody, when. — If either parent of a child changes his residence to another state, such change of residence of the parent shall be deemed a change of circumstances under section 452.410, allowing the court to modify a prior visitation or custody decree.

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(L. 1988 H.B. 1272, et al. § 10, A.L. 1998 S.B. 910)

(2002) Section only applies when relocation occurs in violation of section 452.377. Baxley v. Jarred, 91 S.W.3d 192 (Mo.App.W.D.).

Notes of Decisions

Cited in 21 cases, 1991–2014 · leading case: Baxley v. Jarred, 91 S.W.3d 192 (Mo. Ct. App. 2002).

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Baxley v. Jarred, 91 S.W.3d 192 (Mo. Ct. App. 2002). · cites it 4× “In apparent conflict with the foregoing interpretation is § 452.411. It provides: “If either parent of a child changes his residence to another state, such change of residence of the parent shall be deemed a change of circumstances under section 452.”

Puisis v. Puisis, 90 S.W.3d 169 (Mo. Ct. App. 2002). · cites it 6× “Section 452.411 provides: If either parent of a child changes his residence to another state, such change of residence of the parent shall be deemed a change of circumstances under section 452.”

Dixon v. Dixon, 62 S.W.3d 589 (Mo. Ct. App. 2001). · cites it 3× “Section 452.411 RSMo 1994. Also, due to Mother’s work schedule, the child is in daycare at twelve-hour intervals several days a week, when previously she was not.”

Humphrey v. Humphrey, 888 S.W.2d 342 (Mo. Ct. App. 1994). · cites it 3× “(b) [Father] believes that [mother] has changed her residence to the State of Arkansas, together with the minor child, which constitutes a change of circumstance under Section 452.411, RSMo., allowing the Court to modify the prior custody decree, (e) [Mother] has repeatedly…”

Lindell v. Coen, 896 S.W.2d 525 (Mo. Ct. App. 1995). · cites it 3× “Section 452.411, RSMo 1994. The trial court found that Coen’s move to Georgia “further fits the pattern of contemptuous denial of [Lindell’s] visitation privileges through any means available, there being no justifiable cause for said move.”

McCubbin v. Taylor, 5 S.W.3d 202 (Mo. Ct. App. 1999). · cites it 3× “Although section 452.411, RSMo Cum.Supp.1998, identifies a change of residence from one state to another as a change of circumstances which could support a court’s modification of a prior custody determination, the statute does not provide that a mere change from one Missouri…”

In Re Marriage of Alred, 291 S.W.3d 328 (Mo. Ct. App. 2009). · cites it 2× “” Section 452.411 states that “[i]f either parent of a child changes his residence to another state, such change of residence of the parent shall be deemed a change of circumstances under section 452.”

Sanders v. Busch, 123 S.W.3d 311 (Mo. Ct. App. 2003). · cites it 4× “Mother’s argument disregards Section 452.411, which provides: If either parent of a child changes his residence to another state, such change of residence of the parent shall be deemed a change of circumstances under Section 452.”

Hoefer v. Hoefer, 860 S.W.2d 376 (Mo. Ct. App. 1993). · cites it 5× “Husband contends that there was a change in circumstances in accordance with § 452.411, RSMo Supp.1992 when Wife moved from the State of Missouri to the State of Kansas.”

In Re Marriage of Lowe, 860 S.W.2d 813 (Mo. Ct. App. 1993). · cites it 3× “Section 452.411, RSMo Supp.1988, reads: If either parent of a child changes his residence to another state, such change of residence of the parent shall be deemed a change of circumstances under section 452.”

Bohac v. Akbani, 29 S.W.3d 407 (Mo. Ct. App. 2000). · cites it 2× “However, the record indicates that Mother had changed the children's residence to Illinois, in violation of section 452.411, which provides that such an action constitutes a change of circumstances allowing the court to modify a prior custody decree.”

Michel v. Michel, 834 S.W.2d 773 (Mo. Ct. App. 1992). “§ 452.411. However, it is established that the right of a custodial parent to change a place of residence is not, by those statutes, totally insubordinate to the wishes of the other parent irrespective of the other relevant factors.”

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