Burns v. Burns
2017-0343 (La.App. 1 Cir. 11/3/17), 236 So.3d 571
The First Circuit Court of Appeal reversed a trial court judgment naming the father domiciliary parent. In finding in favor of the mother, the appellate court found the father failed to prove that his remarriage and his disapproval of mother’s boyfriend and lifestyle were material change in circumstances warranting modification of prior custody decree. The father offered no evidence of effect that mother’s actions had on the children.