Father’s relocation with child out of state was a substantial change in circumstances warranting hearing to determine whether modification of custody since entry of last custody order, which had awarded father primary physical custody upon divorce, served child’s best interests; although father and mother were already separated by hundreds of miles, both still lived in Alaska, and father’s out‑of‑state move to Arizona would have meant that visitation would become more costly and more time‑consuming for mother, and that visitation may have occurred less frequently with fewer opportunities for child to visit with extended family living in Alaska.
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Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her website. www.famlawconsult.com
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