Jones v. Jones (1996)
In Jones v. Jones, 326 Ark. 481, 931 S.W.2d 767 (1996), the noncustodial parent's remarriage was one of three changes in circumstances identified by the chancellor in support of his decision to change custody.
In reversing the chancellor's order, the supreme court noted the majority view that a change in circumstances of the noncustodial parent, including a claim of an improved life because of a recent marriage, is not sufficient to justify modifying custody.
In that case, the court did not agree that the noncustodial parent's remarriage was a material change in circumstances because the marriage was reasonably contemplated at the time the agreed custody order was entered.