Galland v. Galland, 117 So. 3d 105

Heidi and Grady Galland married in 2004 and have two children, Colin (8) and Cadence (3).
They divorced in 2009 with a joint custody and co-domiciliary arrangement (7/7 custody).
Heidi moved to Alexandria, prompting Grady to seek and obtain an order for Colin to attend St. Mary’s for 2010-2011; Colin attended St. Mary’s that year.
In 2011 Grady sought psychological evaluations; Heidi filed a Rule to Declare School to enroll Colin at Nachman; multiple motions followed while evaluations occurred.
Dr. Lonowski recommended Colin remain at Nachman for stability and academic superiority; he also noted Nachman’s favorable teacher-student ratio.
The trial court, after evidence and stipulations, granted joint custody with Grady as primary domiciliary parent and ordered both children to attend St. Mary’s; Heidi appeals the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Primary domiciliary status to Grady was properly before the court?	Galland contends custody was not pled; court expanded pleadings unilaterally.	Grady argues the court acted within its authority extent of the pleadings?	Reversed: trial court exceeded its authority by changing domiciliary status.
Whether both children should attend St. Mary’s vs Nachman?	Nachman is academically superior; school choice should be independent of custody.	St. Mary’s is preferable for Colin based on family proximity and familiarity; custody implications allowed consideration of school.	Reversed: school choice improperly intertwined with custody; Nachman favored.

Domingue v. Bodin, 996 So.2d 654 (La.App. 3 Cir. 2008) (court cannot decide a controversy not regularly brought before it; without pleadings amendment, judgment is void)
Evans v. Lungrin, 708 So.2d 781 (La. 2d 1998) (de novo review when legal error affects outcome in custody cases)
Ussery v. Ussery, 583 So.2d 838 (La.App. 2 Cir. 1991) (trial court may grant relief beyond pleadings under certain circumstances but not when the controversy wasn't properly brought)