NORTHEAST POLK COUNTY HOSPITAL DISTRICT

v.

WILLIAMS

Citator

Cited By

• Karie Lynn Gibbs v. Gibbs, 686 So. 2d 639 (Fla. 2d DCA 1996)
  …ourt stated that an initial custody determination should not be “materially amended or changed afterward, unless on altered conditions shown to have arisen since the decree_” Thereafter, in Ritsi v. Ritsi, 160 So. 2d 159 (Fla. 3d DCA), cert. denied, 166 So. 2d 591 (Fla.1964), the court provided a good discussion of the problem and, citing to Frazier, described the second prong of the test as an “essential to the welfare” test: The rule applied on a petition to modify a decree for custody is that while the we…
• Young v. Hector, 740 So. 2d 1153 (Fla. 3d DCA 1998)
  …s of a final judgment may be made only when there has been a change of circumstances adversely affecting the welfare of the children. Belford v. Belford, 159 Fla. 547, 32 So. 2d 312 (1947); Ritsi v. Ritsi, 160 So. 2d 159 (Fla. 3d DCA), cert. denied, 166 So. 2d 591 (Fla.1964). When, as here, the children have manifestly benefitted from an arrangement established before the judgment, the same rule should apply. What happens when that rule is not applied is illustrated by the result in this very case, in which…
• Hutchins v. Hutchins, 220 So. 2d 438 (Fla. 2d DCA 1969)
  …N, J., concur. . Fields v. Fields (1940), 143 Fla. 886, 197 So. 530; Julian v. Julian (2d D.C.A. 1966), 188 So. 2d 896; Bargeon v. Bargeon (2d D.C.A.1963), 153 So. 2d 10. . See Ritsi v. Ritsi (3d D.C.A.1964), 160 So. 2d 159, cert. den. (Fla.1964), 166 So. 2d 591, for a good discussion of this rule, including citation of authorities. In Ritsi custody was originally awarded to the father. The fact that the mother had re-married and had become more affluent than the father was held not to sustain a change of c…