Court of Appeals of North Carolina December 1, 1987, No. 8712DC316 (Hinton v. Hinton)
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United States · · · 01-12-1987
PHILLIPS, Judge.
When the custody of a child has been judicially established custody can be changed by subsequent order only upon it appearing that there has been a substantial change in circumstances that affects the welfare of the child. Shepherd v. Shepherd, 273 N.C. 71, 159 S.E. 2d 357 (1968); Rothman v. Rothman, 6 N.C. App. 401, 170 S.E. 2d 140 (1969); G.S. 5043.7(a).
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