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Marriage of Goodwin-Mitchell and Mitchell
Judgment of nullity based on fraud under Family Code Section 2210(d) must be reversed because the parties continued to cohabit long after husband's infidelity was discovered. 		Family Law 1DCA/3 Sep. 26, 2019
In re A.E.
Under California Penal Code Section 361.5(c)(2), reunification services will not be provided if by clear and convincing evidence it is not in the child's best interests. 		Family Law 4DCA/2 Aug. 23, 2019
S.C. v. G.S.
Under Family Code Section 3603 and 2692, child support payments may not be modified retroactively and trial courts lack the authority to make such modifications. 		Family Law 6DCA Aug. 12, 2019
In re E.W.
California court was not divested of jurisdiction under Uniform Child Custody Jurisdiction and Enforcement Act Section 3422(a)(1) because mother failed to establish all required conditions. 		Family Law 2DCA/8 Jul. 31, 2019
Marriage of Ankola
Family Code Section 6305(a)(1) precludes the court from granting a mutual restraining order unless both parties appear before the court and submit evidence with the mandatory form. 		Family Law 6DCA Jun. 21, 2019
Greiner v. Keller
Family Code Section 4062 requires trial court to order award for childcare costs related to parent's reasonably necessary education or training to secure fully self-supporting employment; thus, denial of request reversed. 		Family Law 1DCA/3 Jun. 18, 2019
Marriage of Miotke
Appellant failed to raise the issue of unconscionability of a premarital agreement at the time of enforcement, and thus she could not raise the issue on appeal. 		Family Law 6DCA May 30, 2019
Lugo v. Corona
The Domestic Violence Prevention Act allows for both criminal and civil protective orders to coexist; thus, the trial court erred in denying plaintiffs domestic violence restraining order request. 		Family Law 2DCA/4 May 30, 2019
In re Marriage of George & Deamon
The family court did not err in awarding sanctions based on declaration and documentary evidence alone; thus, the order is affirmed. 		Family Law 4DCA/1 May 20, 2019
In re Marriage of Kent
At the time it ruled, family court lacked jurisdiction under Uniform Child Custody Jurisdiction and Enforcement Act to modify North Carolina order; thus, family court's order reversed. 		Family Law 4DCA/1 May 20, 2019
In re H.D.
Although mother failed to communicate with and financially support daughters for over a year while getting clean and sober, she did not intend to abandon them; thus, termination of parental rights reversed. 		Family Law 4DCA/2 May 10, 2019
County of San Diego Dept. of Child Support Services v. C.A.
Under Family Code Section 3951(a), parent is not obligated to compensate relative for voluntary support of parent's child, but once relative has legal physical custody, support is no longer voluntary. 		Family Law 4DCA/1 Apr. 24, 2019
N.T. v. H.T.
Knowing violations of a TRO justified issuing a domestic violence restraining order (DVRO), and the particular acts alleged would have independently qualified as abuse supporting the issuance of a DVRO. 		Family Law 4DCA/3 Apr. 23, 2019
Look v. Penovatz
Family Code Section 3950 does not apply if child support is being paid by the parent from whom reimbursement is being sought. 		Family Law 6DCA Apr. 10, 2019
County of San Diego Dept. of Child Support Services v. C.P.
Current Family Code Section 4007.5 applies only to child support orders issued or modified on or after October 8, 2015 and does not save statutory protections of former Section 4007.5. 		Family Law 4DCA/1 Apr. 9, 2019
Molinaro v. Molinaro
Piece of restraining order forbidding Facebook posts about divorce are unconstitutionally overbroad prior restraints. 		Family Law 2DCA/3 Apr. 1, 2019
Marriage of Brooks
Substantial evidence supported trial court's finding that contributions of others, rather than Husband's contributions, caused increase in business's value after date of marriage; thus, 'Van Camp' apportionment method was properly applied. 		Family Law 6DCA Mar. 29, 2019
Marriage of Oliverez
At dissolution of marriage, it is in the trial court's discretion to set a property valuation either at the time of remand or at the date of trial 		Family Law 6DCA Mar. 27, 2019
Marriage of C.T. and R.B.
Courts considering changing physical custody of a child shall consider factors stated in *In re Marriage of LaMusga* and decline relocation if it is not in the child's best interest. 		Family Law 4DCA/2 Mar. 21, 2019
Marriage of Martin
Family Code section automatically terminating spousal support when receiving spouse remarries has no effect where parties waive the statute by leaving box unchecked in support agreement giving effect to section. 		Family Law 4DCA/2 Mar. 12, 2019
Marriage of Ciprari
Direct tracing and exhaustion tracing are not the two 'exclusive' methods of tracing under California. Instead, tracing methods may vary depending on the facts in each case. 		Family Law 2DCA/1 Feb. 8, 2019
In re M.F.
A court may find that reasonable services were not provided or offered when services were not accessible, delays in providing services occurred or the services were not appropriately tailored to a parent's needs. 		Family Law 4DCA/1 Feb. 7, 2019
Marriage of Anka & Yeager
If an attorney intentionally asks numerous questions that disclose confidential information from a custody evaluation report, that attorney can be sanctioned under Family Code Section 3111(f). 		Family Law 2DCA/6 Feb. 6, 2019
Perow v. Uzelac
Under Family Code Section 213, a party does not change or expand the message - and hence does not seek affirmative relief - if a party is only seeking costs. 		Family Law 2DCA/2 Feb. 4, 2019
Guardianship of C.E.
Consolidation of a guardianship proceeding into an adoption proceeding is mandatory under Family Code Section 8802(d) when a petition for adoptions arises after a child is the subject of a guardianship petition. 		Family Law 6DCA Feb. 4, 2019
In re Roger S.
Under Welfare and Institutions Code Section 300(b), continuously having foul body odor and dirty clothes as school, does not indicate that a child is at substantial risk of physical harm or illness. 		Family Law 2DCA/1 Jan. 25, 2019
In re Marriage of Begian & Sarajian
Family Code Section 852(a) creates a presumption that transactions between spouses are not "transmutations," unless evidence in a transaction document definitively reveals the adversely affected spouse's intentions to transmute their property. 		Family Law 2DCA/3 Jan. 23, 2019
County of Riverside v. Estabrook
Under Family Code Section 7551, genetic testing was mandatory because there was a civil proceeding, paternity was a relevant fact, it was timely requested by a party, and testing would be for father. 		Family Law 4DCA/2 Jan. 9, 2019
Modification: W.M. v. V.A.
Trial court erred when it found it could not exercise its jurisdiction under Uniform Child Custody Jurisdiction and Enforcement Act; notice and opportunity to be heard was not given. 		Family Law 2DCA/8 Jan. 4, 2019
Modification: S.Y. v. Superior Court
Abuse of discretion to rely on English fluency when deeming past domestic abuser rebutted presumption that granting him custody would be to child's detriment; but, overall, factors support such a finding. 		Family Law 4DCA/1 Dec. 21, 2018
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