JUDGMENT OF MAY 31, 1988 — CHILD CUSTODY The procedural history and law of this case is as set forth in Parker v. Parker, 559 So.2d 37 (La.App. 4 Cir. 1990). In that case this court vacated a judgment awarding custody of Lana and Dana Parker to their mother, the appellee, Diana M. Parker.
Thus, in addition to the paramount best interest of the child standard, this Circuit applies the heavy burden of proof rule, the change of circumstances rule, and the appellate standard of review rule to change of custody matters which follow consent judgments. Parker v. Parker, 559 So.2d 37 (La.App. 4th Cir. 1990). Additionally, a child's preference to live with a different parent is not, of itself, a material change of circumstances affecting the child's welfare.