Jane J. v. Superior Court of Orange County (2015)

Appellate courts are less restrained in reviewing custody modifications for abuse of discretion than in most other contexts; Discussing burden of proof for modifications; When shifting primary custody to non-custodial parent who lived out of state, court abused discretion by not considering move-away factors as well as change-of-custody factors; Peremptory writ in first instance vacating modification is appropriate remedy