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Case Citations [i] (Fall 2025)

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                          THE AMERICAN


                          LAW INSTITUTE



                                  Fall 2025 Citations



        PRINCIPLES OF THE LAW OF FAMILY

               DISSOLUTION: ANALYSIS AND

                       RECOMMENDATIONS



       CHAPTER   2. THE ALLOCATION OF CUSTODIAL AND DECISIONMAKING
                          RESPONSIBILITY   FOR  CHILDREN

                               TOPIC  3. FACTFINDING

§ 2.13 Court-Ordered Investigation; Appointment of Guardian ad Litem or Lawyer for the Child

Kan.App.2025. Com. (g) quot. in sup. In divorce proceedings, mother of three children challenged the
trial court's admission of her psychological evaluation and parenting assessment in a child-custody
hearing at the request of the guardian ad litem appointed to represent the children's interests, arguing
that the state statute concerning investigations in child-custody proceedings could only require the
mental health examinations of a child. Affirming, this court held that the statute could be used to order
the psychological evaluations of parents in contested child-custody proceedings. The court cited the
Principles of the Law of Family Dissolution: Analysis and Recommendations § 2.13 in noting that the
statute expanded the investigator's authority, rather than contracted it, to permit the psychological
examinations of parents for the purpose of determining the most beneficial custodial arrangement for
their children. Matter of Marriage of L.F. and M.F., 562 P.3d 1014, 1023.











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