In re Marriage of Hadeen
Court of Appeals of Washington
619 P.2d 374 (Wash. App. 1980)
Judith Hadeen (plaintiff) sought custody of her and Glen Hadeen's (defendant) five children in their divorce. Judith followed a Christian sect emphasizing strict, controlling discipline, and sometimes used spanking and isolation on the children. Glen, a former member of the same church, testified its members were taught not to associate with nonbelievers. After interviewing the children and reviewing a court-appointed psychiatrist's report, the trial court found Judith provided proper care and that the children were well-adjusted and bonded with both parents — but concluded Judith's strict adherence to the church harmed her other relationships, and disregarded the psychiatrist's recommendation that Judith retain custody if the church-related issues were addressed. The court awarded the oldest child to Judith and the other four to Glen. Judith appealed.
Whether, in making a best-interests-of-the-child custody determination, a trial court may consider a parent's religion only to the extent the religion creates a reasonable and substantial likelihood of immediate or future harm to the child's mental health or physical safety.