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In re Interest of M.M.

Court of Appeals of Iowa.
Jul 27, 2016
885 N.W.2d 831 (Iowa Ct. App. 2016)
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Summary

concluding "the juvenile court need not find a substantial change in circumstances as a prerequisite to modification of a dispositional order"

Summary of this case from In re C.C.
See 4 Summaries

Opinion

No. 16–0548.

07-27-2016

In the Interest of M.M. and I.M., Minor children. O.F., Father, Appellant. J.M., Mother, Appellant.

Philip L. Garland, Garner, for appellant father. Jane M. Wright, Forest City, for appellant mother. Thomas J. Miller, Attorney General, and Mary A. Triick, Assistant Attorney General, for appellee State. Theodore J. Hovda, Garner, for minor children.

DECISION WITHOUT PUBLISHED OPINION

Affirmed on both Appeals.

Summaries of

In re Interest of M.M.

Court of Appeals of Iowa.
Jul 27, 2016
885 N.W.2d 831 (Iowa Ct. App. 2016)

concluding "the juvenile court need not find a substantial change in circumstances as a prerequisite to modification of a dispositional order"

Summary of this case from In re C.C.

noting the 2004 amendments to the statute superseded caselaw requiring proof of a material and substantial change in circumstances as a prerequisite to modification

Summary of this case from In re A.P.

noting supreme court case law provides that "modification of custody or placement requires a material and substantial change in circumstances," but concluding later amendment of the statute by the legislature which does not include a requirement that a change of circumstances be proved "is controlling" and no such finding need be made

Summary of this case from In re E.G.

questioning the rule requiring a material and substantial change in circumstances before modifying the custody provision of a prior dispositional order in a CINA action because such a showing is not mandated by statute

Summary of this case from In re A.J.
Case details for

In re Interest of M.M.

Case Details

Full title:In the Interest of M.M. and I.M., Minor children. O.F., Father, Appellant…

Court:Court of Appeals of Iowa.

Date published: Jul 27, 2016

Citations

885 N.W.2d 831 (Iowa Ct. App. 2016)

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