Doe v. Doe
Supreme Court of Idaho
239 P.3d 774 (Idaho 2010)
John Doe (plaintiff) and Jane Doe (defendant) divorced under a decree giving them joint legal and physical custody of their child, with Jane having primary physical custody. After the divorce, Jane repeatedly obstructed John's visitation, lied about the child being sick to block visits, and made false accusations aimed at cutting John out. A court-appointed expert found Jane's erratic behavior was harming the child's relationship with John. John petitioned to modify the decree for sole legal and primary physical custody, and the trial court granted it, finding Jane irrational about sharing custody. Jane appealed.
Whether a party seeking to modify a custody order must show a material and substantial change in circumstances since the last order and that the modification serves the child's best interests.