This family law decision addresses the question of whether the trial court erred when it changed the custody of a child from the mother to the father. When the parents dissolved their marriage, the mother was designated as the primary residential parent and the father was to pay child support. When the mother wanted to relocate out-of-state she requested a modification of the original visitation schedule. The father responded with a request for a change of custody, or in the alternative, that he no longer be required to pay child support. The trial court found that it would be in the "best interest" of the child to be placed into the custody of the father. On appeal, the Court reverses the lower court's decision. The Appellate Court agreed that the out-of-state move may have constituted a "substantial change in circumstances." However, there was no evidence to support that it would have been in the child's "best interest" to be relocated with the father. The reviewing court found that the father did not meet "the evidentiary burden required to change custody in a modification context."
1. Why did the appellate court reverse the decision of the trial court?
2. Explain the facts that brought about the father's letter to the court.