Burr v. Burr, 2015 Ark. App. 640

Jason and Alisha Burr divorced after marriage in 2004; two minor children (E.B. and J.B.).
Jason filed for divorce and custody in May 2012; temporary custody was awarded to Alisha with a recurring visitation schedule for Jason and monthly child support ordered ($2,800/month).
The court ordered family counseling with counselor Pat Howard; disputes arose (Alisha attended few sessions; Howard raised concerns about Alisha’s pending criminal charges and parental influence over E.B.).
Alisha later pled no contest to arson and multiple aggravated-assault and criminal-mischief counts and was serving weekend jail time; the circuit court delayed a final custody ruling pending resolution of those charges.
The court ultimately made the temporary-visitation schedule permanent in a supplemental order (February 2015), awarded primary custody to Alisha, and continued Jason’s visitation and child-support obligations; Jason timely appealed.

Issue	Plaintiff's Argument (Jason)	Defendant's Argument (Alisha)	Held
Whether the court erred in awarding primary custody to Alisha	Alisha’s criminal convictions and unstable lifestyle render her unfit; custody should be awarded to Jason	The existing temporary schedule had worked well, children were doing well, and little in the record showed the convictions impaired Alisha’s parenting	Court affirmed: granting custody to Alisha was not clearly erroneous

Taylor v. Taylor, 345 Ark. 300 (discusses deference to trial court on credibility in custody cases and that children's best interest is the guiding principle)
Rector v. Rector, 58 Ark. App. 132, 947 S.W.2d 389 (lists factors for child’s best interest: psychological relationship, stability/continuity, past parental conduct, child’s reasonable preference)