FOCUS COLUMN
By Mitchell A. Jacobs and T. Elizabeth Fields
This article appears on Page 5
The recent 4th District Court of Appeal decision, In re Marriage of Lucio, 161 Cal.App. 4th 1068 (2008), establishes a bright-line rule that requires a best interests standard of review, for family law requests to modify visitation orders. The Lucio decision also makes it clear that a parent's physical or leg...
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