Crystal Schachle v. Seth Schachle, S19400

Crystal and Seth Schachle divorced and disputed custody of their two children after Crystal was diagnosed with multiple sclerosis and wanted to relocate to Missouri for treatment and to live near her new husband. 1
In interim custody proceedings, the superior court found both parents had anger issues and engaged in mutual misconduct, and it ordered shared physical custody in Alaska. 2
At the final custody trial, Crystal sought sole legal custody and primary physical custody in Missouri, while Seth sought shared legal custody and primary physical custody in Alaska. 3
The superior court found Crystal's relocation legitimate but concluded the children's best interests favored remaining in Alaska under shared custody with Seth. 4
Crystal moved for reconsideration, arguing the court failed to apply a symmetrical best-interests analysis and erred on the children's PFD management, and the court denied the motion. 5
The supreme court vacated the physical custody order and remanded for further findings, but affirmed the PFD ruling. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the superior court apply the required symmetrical relocation analysis? 7	Crystal argued the court compared the wrong custody scenarios and failed to assume relocation.	Seth argued the court properly found relocation was not in the children's best interests.	No; the court made insufficient findings, so custody order vacated and remanded. 8
Did the court abuse discretion on children's PFD management? 9	Crystal argued Seth should not be authorized to manage the PFDs.	Seth argued the arrangement protected the children's interests amid parental conflict.	No; the PFD ruling was affirmed. 10

Meier v. Cloud, 34 P.3d 1274 (Alaska 2001) (continuity and stability analysis may favor a relocating parent with superior emotional stability 11)
Mengisteab v. Oates, 425 P.3d 80 (Alaska 2018) (custody analysis must be symmetrical and consider both post-relocation scenarios 12)
Moeller-Prokosch v. Prokosch, 27 P.3d 314 (Alaska 2001) (requires two-step relocation custody analysis and may require two best-interests determinations 13)
Moeller-Prokosch v. Prokosch, 53 P.3d 152 (Alaska 2002) (a legitimate move cannot be held against the relocating parent 14)
Moeller-Prokosch v. Prokosch, 99 P.3d 531 (Alaska 2004) (continuity and stability requires comprehensive, symmetrical inquiry 15)
Brett M. v. Amanda M., 445 P.3d 1005 (Alaska 2019) (insufficient findings for appellate review are legal error 16)
Ronny M. v. Nanette H., 303 P.3d 392 (Alaska 2013) (trial courts have broad discretion over who manages children's PFDs 17)
Roman v. Karren, 461 P.3d 1252 (Alaska 2020) (appellate courts do not substitute judgment for discretionary trial-court decisions 18)
Saffir v. Wheeler, 436 P.3d 1009 (Alaska 2019) (de novo review applies to whether a court conducted the proper symmetrical analysis 19)