Standard for Modification of Primary Residential Parent or Parenting Schedule

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In  NANCY LYNN HOPPER v. ANTHONY ANGELO DEBBOLI, the Court of Appeals restates the standard for modification of the primary residential parent or the residential parenting schedule.
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“A succinct explanation of the framework for such a determination was set forth by this Court in Burnett v. Burnett:   
 
We apply the two-step analysis in Tennessee Code Annotated § 36-6101(a) (2014) to requests for modification of the primary residential parent or the residential parenting schedule.  See, e.g., In re T.C.D., 261 S.W.3d at 743 (primary residential parent modification); In re C.R.D., No. M200502376-COA-R3-JV, 2007 WL 2491821, at *6 (Tenn. Ct. App. Sept. 4, 2007) (residential parenting schedule modification).  The threshold issue is whether a material change in circumstance has occurred since the court’s prior custody order. See Tenn. Code Ann. § 36-6-101(a)(2)(B); Armbrister, 414 S.W.3d at 697–98.  Only after it is determined that a material change in circumstance has occurred must the court determine whether modification is in the child’s best interest.  Armbrister, 414 S.W.3d at 705.”