What is the test for abuse of discretion in a custody order?

California, United States of America


The following excerpt is from Lukoff v. Lukoff (In re Lukoff), C/w G054697, G054525 (Cal. App. 2018):

We review custody orders for abuse of discretion. "The precise measure is whether the trial court could have reasonably concluded that the order in question advanced the 'best interest' of the child." (In re Marriage of Burgess (1996) 13 Cal.4th 25, 32; cf. Cassady v. Signorellli (1996) 49 Cal.App.4th 55, 61-62 [order giving father final decision in child's health care not abuse of discretion].)

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