Family
Sep. 13, 2000
Higher Hurdle
Montenegro continues the trend of reinforcing and tightening the changed-circumstances requirement.
The recent case of Montenegro v. Diaz, 97 Cal.Rptr.2d 782 (2000), raises a little higher the obstacle of presenting a factual "change of circumstances," which must be hurdled by a custody litigant seeking to modify a permanent decree of custody and visi...
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