CHANGE IN CUSTODY - RECENT CASE

I have been reading a number of recent cases of custody changes from one spouse to another. This one I found interesting:

Matter of Stones v Vandenberge 2015 NY Slip Op 03546 Decided on April 29, 2015 Appellate Division, Second Department:

"Contrary to the mother's contention, there was sufficient evidence in the hearing record both to demonstrate the requisite change in circumstances and to support the Family Court's determination modifying the 2009 custody order by awarding custody to the father. While it would have been preferable for the court to consider forensic evaluations of the parties and the child in reaching its custody determination, under the particular circumstances of this case, there was ample testimony and documentary evidence upon which the court could determine the best interests of the child. The custody determination has a sound and substantial basis in the record, and we discern no basis for disturbing it."