FRANCES SHARON JAYNE, FORMERLY FRANCES SHARON DENNISON, APPELLANT,
v.
CALVIN B. DENNISON, APPELLEE
• COWART, JOE A., Jr., Associate Judge.
The appellant claims that every order changing custody must include a finding that the prior custodian is unfit. This is not correct. There need only be a substantial, material change of circumstances that strongly infers a change of custody would .promote the welfare of the child. Negative factors in the mother’s circumstances, short of unfitness, when coupled with intervening special needs of the child and increased ability of the father to provide for the child may be sufficient to justify a change. While unfitness is entitled to much weight, and is a factor often noted in the cases, it is not an absolute prerequisite to a change.
The appealed order is Affirmed.
MANN, C. J., and BOARDMAN, J., concur.
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Stricklin v. Stricklin, 383 So. 2d 1183 (Fla. 5th DCA 1980)…ive factors in the circumstances of the custodial parent when coupled with the intervening special needs of the child and increased ability of the non-custodial parent to provide for the child, may be sufficient to justify change. Jayne v. Dennison, 284 So. 2d 237 (Fla. 2d DCA 1973). However, the fact that the father had remarried, that the mother was working while her parents cared for the child, that she was having marital difficulties and that she had changed her place of residence several times, was not s…
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McINTYRE v. Nance Ruth McINTYRE, 452 So. 2d 14 (Fla. 1st DCA 1984)…ive factors in the circumstances of the custodial parent when coupled with the intervening special needs of the child and increased ability of the non-custodial parent to provide for the child, may be sufficient to justify change. Jayne v. Dennison, 284 So. 2d 237 (Fla. 2d DCA 1973). However, the fact that the father had remarried, that the mother was working while her parents cared for the child, that she was having marital difficulties and that she [*25] had changed her place of residence several times, was…
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Shaw v. Shaw, 455 So. 2d 1156 (Fla. 5th DCA 1984)…ies, the applicability of the following cases should be considered: Gorman v. Gorman, 400 So. 2d 75 (Fla. 5th DCA 1981); Johnson v. Richardson, 434 So. 2d 972 (Fla. 5th DCA 1983); Pape v. Pape, 444 So. 2d 1058 (Fla. 1st DCA 1984); Jayne v. Dennison, 284 So. 2d 237 (Fla. 2d DCA 1973), cert. denied, 293 So. 2d 713 (Fla.1974).…
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