In Re: The Marriage of Ann (Sutton) Baker v. Milo Sutton, 16 N.E.3d 481

Parents divorced in 1999; Mother had sole legal and physical custody; Father had parenting time under IPTG and later additional time until 2010; Father petitioned for change of custody in 2013; trial court held an in camera interview with Child and issued findings highlighting Child’s closeness with Father, interest in golf and computers, and Mother’s overbearing tendencies; Child expressed desire to live with Father leading to the custody modification awarding Father sole custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether modification of custody was proper.	Mother argues modification was not warranted.	Father argues substantial changes and best interests support modification.	Not clearly erroneous; modification affirmed.

Jarrell v. Jarrell, 5 N.E.3d 1186 (Ind. Ct. App. 2014) (standard for reviewing custody modifications)
Julie C. v. Andrew C., 924 N.E.2d 1249 (Ind. Ct. App. 2010) (findings control only for issues covered; clear error standard)
Parks v. Grube, 934 N.E.2d 111 (Ind. Ct. App. 2010) (child’s wishes plus other factors support modification)
Williamson v. Williamson, 825 N.E.2d 33 (Ind. Ct. App. 2005) (child’s wishes considered with other factors in modification)
In re K.I., 903 N.E.2d 453 (Ind. 2009) (substantial change in any factor may support modification)
Robertson v. Robertson, 634 N.E.2d 93 (Ind. Ct. App. 1994) (older standard; evidence support required for modification)