Manuela Baker v. Michael R. Jones, 16-1164

Parents (Manuela "Mandie" Baker and Michael Jones) share a five-year-old son, E.J.; they never married but had alternating week joint physical care since separation in 2014.
Mandie sought to relocate to Louisiana for a higher-paying employer position and filed to establish custody, visitation, and support in anticipation of the move.
District court found joint physical care infeasible if Mandie relocates; awarded joint week-to-week care until she moves, then primary physical care to Mandie with an extensive visitation schedule for Michael (summer, spring break, selected weekends, plus limited Louisiana visitation); Mandie to provide health insurance; Michael to pay child support; Mandie to pay E.J.’s travel for visitation.
Michael appealed, arguing the child’s support system (half-sibling and extended family) is in Iowa and the child should remain with him if Mandie moves.
On de novo review, the Court of Appeals affirmed, concluding Mandie has been the primary caregiver, her Louisiana job schedule is conducive to caregiving, and placement with Mandie best serves the child’s long-term best interests.

Issue	Plaintiff's Argument (Mandie)	Defendant's Argument (Michael)	Held
Whether joint physical care should continue after Mandie’s relocation	Joint care worked previously; relocation makes joint care impracticable but Mandie should have primary care upon move	Child should remain in Iowa with Michael because E.J.’s support system is here and relocation harms the child	Joint care appropriate only until move; upon Mandie’s relocation, primary physical care awarded to Mandie
Which parent’s custody serves child’s best interests	Mandie is primary caregiver, arranges medical/activities, has stable job offering suitable hours in LA	Relocation severs child’s local supports (half-sibling, extended family); Mandie lacked finalized housing/school plans at trial	Placement with Mandie best serves long-term best interests given caregiving history and employment/hours in LA
Visitation scope after relocation	Mandie proposed arrangements accommodating Michael’s contact	Michael sought substantial ongoing in-state custody/primary care	Court adopted visitation: extended summer, spring break, certain weekends, monthly LA weekend and two weeks school year; travel costs borne by Mandie
Appellate attorney fees request	Mandie requested fees as prevailing party on appeal	Michael opposed	Court declined to award appellate attorney fees

Dye v. Geiger, 554 N.W.2d 538 (Iowa 1996) (distinguishes paternity determinations from ancillary equitable matters such as custody)
Mason v. Hall, 419 N.W.2d 367 (Iowa 1988) (equitable review applies to custody/support issues ancillary to paternity)
In re Marriage of Fennelly, 737 N.W.2d 97 (Iowa 2007) (de novo review standard for equitable family law matters)
In re Marriage of Brown, 778 N.W.2d 47 (Iowa Ct. App. 2009) (trial-court factual findings, especially credibility, are given weight on appeal)
Lambert v. Everist, 418 N.W.2d 40 (Iowa 1988) (best-interests standard for child custody placements)
In re Marriage of Winter, 223 N.W.2d 165 (Iowa 1974) (factors to consider in custody determinations)
In re Marriage of Shanklin, 484 N.W.2d 618 (Iowa Ct. App. 1992) (long-term best interests are the governing consideration in custody disputes)
In re Marriage of Quirk-Edwards, 509 N.W.2d 476 (Iowa 1993) (siblings/half-siblings should not be separated except for compelling reasons)
In re Marriage of Sullins, 715 N.W.2d 242 (Iowa 2006) (factors for awarding attorney fees in family-law appeals)