Section 9.10 Stability

• Library: Family Law Deskbook and 2014 Supp

C. (§9.10) Stability

Frequent moves by a parent inhibit the stability of a child and are usually disfavored by the courts. In Adair v. Adair, 760 S.W.2d 544 (Mo. App. W.D. 1988), custody was awarded to the father because the mother, who was in the military, moved every two years, and the father could provide a stable home in Missouri where he and all the grandparents lived.

But see Senciboy v. Thorpe, 947 S.W.2d 116, 119 (Mo. App. W.D. 1997), in which the court found that the custodial parents’ frequent moves did not warrant modification of custody because the adjustments the child had to make with each move were not significant enough to...