Missouri Court of Appeals, Western District / Date unavailable
David Lee Couzens, Jr. vs. Devyn Lea Post
Mother, Devyn Lea Post, appealed the circuit court's dismissal of her motion to modify a child custody decree. The circuit court had dismissed the motion, concluding that Mother failed to show a sufficient change of circumstances. The appellate court reversed and vacated the circuit court's judgment, holding that a change of residence by either parent to another state constitutes a sufficient change of circumstances to satisfy the first step of a motion to modify custody. The case was remanded for the circuit court to conduct a "best interests of the child" analysis.