Anhalt v. Fesler

In Anhalt v. Fesler, 6 Kan. App. 2d 921, 636 P.2d 224 (1981), the Court stated the custody decree was not a true judicial determination and was more akin to the award of custody in a default proceeding. 6 Kan. App. 2d at 924. The court stated: "Where a custody decree is entered on written stipulation, and the facts are not substantially developed and presented to the court, the trial court may later, in its discretion, admit and consider evidence as to facts existing at the time of the earlier order, and upon the full presentation of the facts the court may enter any order which could have been made at the initial hearing whether a change of circumstances has since occurred or not." 6 Kan. App. 2d 921, Syl. P4.