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Home / Opinion Digests / Domestic Relations – Custody Modification – ‘Most Recent Award’ (access required)

Domestic Relations – Custody Modification – ‘Most Recent Award’ (access required)

A Fairfax Circuit Court says that earlier juvenile court proceeding initiated by Family Services that continued current physical custody arrangements but did not make an award of custody of the child was not “the most recent award of custody” as contemplated by Keel v. Keel, 225 Va. 606 (1983), and the court overrules mother’s “demurrer” ...

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