Snyder v. Snyder, 2015 UT App 245 (Sept. 24, 2015)

Father moved to modify custody two months after the parties resolved a dispute over the amount of child support. Concluding the father failed to show a substantial change in circumstances in the intervening two months since it had accepted the parties’ child support stipulation, the district court dismissed the petition. The Utah Court of Appeals reversed and held the lower court erred when it required the father to show a material change in circumstances in the preceding two months, because the last order addressing the issue of custody occurred years prior to the father’s recent petition.