What is the standard for appellate review of custody and visitation orders?

California, United States of America


The following excerpt is from Verduzco v. Siller, A133248 (Cal. App. 2012):

" 'The standard of appellate review of custody and visitation orders is the deferential abuse of discretion test.' [Citation.] Under this test, we must uphold the trial court 'ruling if it is correct on any basis, regardless of whether such basis was actually invoked.' " (Montenegro v. Diaz (2001) 26 Cal.4th 249, 255 (Montenegro).)

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