Eddie Lamaine Brown v. Chrystal Diane Armstrong Brown

In this appeal involving competing petitions to modify a Virginia residential co-parenting order, the trial court denied both petitions after determining that no material change of circumstance existed warranting modification. Because the trial court did not apply the correct legal standard to its analysis regarding material change of circumstance, we vacate and remand with instructions to apply the proper standard set forth in Armbrister v. Armbrister, 414 S.W.3d 685 (Tenn. 2013). We decline to award Mother her attorney’s fees incurred on appeal.