In Re Marriage of Herrell v. Herrell


144 Wis. 2d 479, 424 N.W.2d 403 (WI Ct. App., 1988)


Circuit court erroneously applied “best interest” standard instead of “necessary” because of stipulation of the parties. The statutory protection to children of the necessary standard would be defeated if parties were allowed to determine a lesser showing to modify a custody award.

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