Burno v. Burno
Burno v. Burno
Opinion of the Court
The former wife, Jennifer Burno, appeals from the partial final judgment granting her former husband, Donald Bur-no’s second amended supplemental petition for modification of child custody. Finding the trial court applied the proper legal standard and did not abuse its discretion, we affirm.
We note that the judgment does not include significant oral findings made at the conclusion of the trial.
AFFIRMED; REMANDED for entry of corrected judgment.
. For instance, the written judgment did not reflect the trial court's findings that the former wife had violated the visitation schedule and regularly made unilateral decisions regarding the children’s upbringing. Those findings supported the trial court’s conclusion that there had been a substantial, material, and unanticipated change in circumstances since entry of the initial judgment.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.