California, United States of America
The following excerpt is from Aracely R. v. Richard M., B272262 (Cal. App. 2017):
By applying the changed circumstances standard and refusing to reevaluate the section 3044 inquiry, the second trial court recognized the December 2015 order as a final custody order. (See Montenegro v. Diaz (2001) 26 Cal.4th 249, 258-259 [the changed circumstances rule applies to final judicial custody determinations]; In re Marriage of LaMusga (2004) 32 Cal.4th 1072, 1088-1089, fn. 2 ["The court's [order] granting joint legal custody to the parties and primary physical custody to the mother, constituted a final judicial custody determination that
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the court need not reconsider in the absence of changed circumstances."].)
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