What is the standard of review of custody and visitation orders at the Court of Appeal?

California, United States of America


The following excerpt is from Blum v. Herbstman (In re Marriage of Blum), H046416 (Cal. App. 2019):

" 'The standard of appellate review of custody and visitation orders is the deferential abuse of discretion test.' [Citation.]" (Montenegro v. Diaz (2001) 26 Cal.4th 249, 255.) A trial court's decision whether to appoint a child custody evaluator is reviewed for an abuse of discretion. (See In re Marriage of E.U. & J.E. (2012) 212 Cal.App.4th 1377, 1389 [decision to appoint an Evidence Code section 730 evaluator

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