Please ensure Javascript is enabled for purposes of website accessibility

Domestic Relations: Child Custody-Modification

Staff Report//July 9, 2026//

Domestic Relations: Child Custody-Modification

Staff Report//July 9, 2026//

Listen to this article

Mother appealed the trial court’s order modifying the parties’ child custody arrangement. On appeal, mother argued that the trial court abused its discretion in failing to compel testimony of a division employee regarding an investigation into father’s claim that the parties’ child’s teacher asked to see child’s genitals. Mother further argued that father failed to show changed circumstances warranting modification of the custody arrangements. Mother also contended that the trial court failed to give full faith and credit to the parties’ prior California child custody order by not making the child support order retroactive due to the California court’s reservation of jurisdiction over support.

Where the division had found father’s claims unsubstantiated, there was no error in excluding the testimony, and there was adequate support for the trial court’s modification judgment because father had followed mother and the child in relocating to Missouri and the record showed that modification was in the child’s best interests.

Judgment is affirmed.

Hunter v. Bernhard (MLW No. 84948/Case No. ED113642 – 16 pages) (Missouri Court of Appeals, Eastern District, Dowd, J.) Appealed from circuit court, St. Louis County, Heggie, J. (Craig Kallen for appellant) (Elaine A. Pudlowski for respondent)

Latest Opinion Digests

See all digests

Top stories

See more news