In accordance with this rule, parties in a domestic relations case are generally responsible for paying their own attorney's fees. Fleming v. Fleming , 446 S.W.3d 677 (Mo. App. W.D. 2014). One exception to the "American Rule" is when a statute allows for the recovery of attorney's fees.
Henry v. Henry , 353 S.W.3d 368, 374 (Mo. App. S.D. 2011).Fleming v. Fleming , 446 S.W.3d 677, 680 (Mo. App. W.D. 2014). Mother suggests that the trial court "misapplied the law" because "[t]he Docket Entry was entirely silent regarding the four factors the court must consider in determining whether a proposed relocation serves the best interest of the child."
See, e.g.,Allen , 390 S.W.3d at 249–51 (holding that the mother could not claim an absolute right to relocate absent "strict compliance" with the notice requirements of section 452.377.2); Fleming v. Fleming, 446 S.W.3d 677, 680–81 (Mo. App. 2014) (same). In emphasizing the need for "strict compliance," both cases relied on Abraham v. Abraham , 352 S.W.3d 617, 619–20 (Mo. App. 2011), in which the Southern District held that "strict compliance" with the provisions of section 452.377.2 is required and acknowledged that its ruling conflicted with Baxley's concept of "actual notice."