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IN RE MARRIAGE OF ZIGLER AND SIDWELL

No. 27378-4-III.

226 P.3d 202 (2010)

In re the MARRIAGE OF Lisa ZIGLER, Appellant, and Kirk SIDWELL, Respondent.

Court of Appeals of Washington, Division 3.

March 4, 2010.

Attorney(s) appearing for the Case

Dustin Douglass Deissner, Van Camp & Deissner, Spokane, WA, for Appellant.

Blaine Thomas Connaughton, Connaughton Law Office, Yakima, WA, for Respondent.

SWEENEY, J.

¶ 1 A trial judge who modifies a parenting plan must find, among other things, that a substantial change in circumstances makes the child's primary residence detrimental to his health. RCW 26.09.260(2)(c). The finding must be based on facts that have arisen since the last contested parenting plan. RCW 26.09.260(1). Here, the trial judge modified a child's primary residence from his mother's house to his father...

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