Doyle v. Doyle, 2011 UT 42

Doyle and Robin Doyle are the parents of Hyrum, who has disabilities; the 2005 divorce awarded Doug sole legal and physical custody; Robin moved to Salt Lake City in reliance on a now-invalid automatic custody provision.
The district court amended the decree to strike the automatic transfer clause and kept Doug as custodial parent; Robin sought modification of custody in 2005 for a change in circumstances.
Robin petitioned in 2005 to modify custody based on: Robin’s relocation to Utah, reliance on prior provision, and need for stability in Hyrum’s life; trial on custody modification occurred in 2007.
Before trial, Doug asked for bifurcation into separate hearings for changed circumstances and best interests; the court denied formal bifurcation but allowed a single hearing with evidentiary overlap.
Robin presented evidence (including Dr. Hale’s custody evaluation) showing Hyrum’s anxiety, schooling issues, and Robin’s involvement; the court found a substantial material change and, after trial, granted Robin sole custody.
The court later modified child support sua sponte under rule 54(c)(1), after letting Doug respond and submit supplemental briefing; the court found support modification appropriate under Utah law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is bifurcation required to separate changed circumstances and best interests?	Doyle argues formal bifurcation is mandated by Hogge.	Doyle contends separate hearings are necessary to avoid taint.	No formal bifurcation required; analytical separation suffices.
Was there a substantial change in circumstances to reopen the custody decree?	Doyle should not be barred from re-evaluating due to prior reliance on past provisions.	Robin’s move back to Utah and Doug’s conduct changed circumstances affecting care.	Yes, there was a material and substantial change sufficient to modify custody.
May the trial court modify child support even without a request in the custody petition?	Doug argues no authority to modify absent a pleading request.	Court had authority under rule 54(c)(1) and implied consent to hear related issues.	Yes; the court had authority to modify support sua sponte and did so within proper procedural rulings.

Hogge v. Hogge, 649 P.2d 51 (Utah 1982) (two-step approach to custody modification; changed circumstances first, then best interests de novo)
Becker v. Becker, 694 P.2d 608 (Utah 1984) (need material change to reach best interests)
Kramer v. Kramer, 738 P.2d 624 (Utah 1987) (change in circumstances must be material to custody issue)
Moody v. Moody, 715 P.2d 507 (Utah 1985) (evidentiary overlap between changed circumstances and best interests allowed)