Custody Law Update: Grungo-Smith v. Grungo

On February 10, 2023, the South Carolina Court of Appeals issued its opinion in Grungo-Smith v. Grungo.  This change of custody case sets out many considerations that might have amounted to a change of circumstances in prior cases.  However, because the children were doing well, no change of custody was ordered.  This is a signal to lawyers to be cognizant that it is not merely various changes in the lives of the parties that one must prove to prevail in a change of custody case, but that one must also prove that the change is in the best interest of the minor child.   Both parents failed to prove that crucial factor in Grungo.

Grungo also contains an admonition against asking a Guardian ad Litem for a recommendation on custody absent exceptional circumstances existing.

The opinion can be found here:

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