BOBBI SPAIN Missouri Cases

Brandon Schiesswohl (Father) appealed the denial of his motion to modify a child custody decree, which sought changes to the parenting schedule and final decision-making authority over Child's healthcare. The trial court had applied a "substantial change in circumstances" standard. The appellate court reversed, holding that the proper standard for modifying a custody arrangement (like parenting schedule or decision-making authority within joint custody) is a "change in circumstances," not a "substantial" one, as Father was not seeking to change the custody designation. The case was remanded for the trial court to apply the correct legal standard.