What is the test for a parent seeking a change in custody of a child when there is a prior order granting the mother permanent custody?
British Columbia, Canada
The following excerpt is from C.R.H. v. B.A.H., 2005 BCCA 277 (CanLII):
In Gordon v. Goertz there was a prior order granting the mother permanent custody. It was in the context of that prior order that the court held that a parent applying for a change in custody must show a material change in circumstances affecting the child.
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