Changing custody requires an adverse change in circumstances adversely affecting the child. It is hard to find a case where both sides of the standard can be met. Even though a court might frown on multiple sexual partners and excessive partying and drinking by a custodial parent, such conduct alone is not enough. There must be evidence the conduct has a negative impact on the child. Carson v. Carson No. 2012-CA-01647-COA (12/3/13)
