Section 21.6 In General

• Library: Family Law (2019 Supp)

1. (§21.6) In General

In 2016, §§ 452.310, 452.340, 452.375, 452.400, 452.556, 454.849, and 454.1728, RSMo, were amended. These statutes address child custody and also parenting plans, motions for contempt, and family access motions, among other topics.

In Holmes v. Holmes, 436 S.W.3d 599 (Mo. App. S.D. 2014), the court cited In re Marriage of Sisk, 937 S.W.2d 727 (Mo. App. S.D. 1996), in concluding that an expert, initially hired by the CD (Missouri Department of Social Services Children’s Division) and then later hired by the father, helped disprove the mother’s allegations of sexual abuse. The court in Holmes awarded sole custody to the father. Note, however, that there is a substantial dissenting opinion in Holmes.

In re S.E., 527 S.W.3d 894 (Mo. App. E.D. 2017), is a termination of parental rights case involving use of expert...