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BRANDON v. COFFEY

Record No. 0440-22-2.

886 S.E.2d 780 (2023)

77 Va. App. 628

Sidney Jordan BRANDON, III v. Laurie COFFEY.

Court of Appeals of Virginia, Richmond.

May 16, 2023.

Attorney(s) appearing for the Case

John S. Koehler (The Law Office of James Steele, PLLC, on brief), for appellant.

Carl J. Witmeyer, II (The Witmeyer Law Firm LLC, on brief), Ashland, for appellee.

Present: Judges Ortiz, Chaney and Senior Judge Haley.

When granting primary physical custody to a parent in an initial custody determination, the trial court need not separately determine whether living out-of-state is in the best interests of the child, if the prospective custodial parent already lives out of state. In...

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