Mullen v. Mullen
In Mullen v. Mullen, 188 Va. 259, 49 S.E.2d 349 (1948), which involved divorced parents residing in different states, the Court observed:
While there are certain disadvantages in dividing or alternating custody, there are also important advantages and benefits.
It gives the child the experience of two separate homes.
The child is entitled to the love, advice, and training of both her father and her mother.
Frequent associations, contact, and friendly relations with both of her parents will protect her future welfare if one of her parents should die.
It gives recognition to the rights of parents who have performed obligations as parents . . . provided such right be exercised for the welfare of the child. Id. at 272-73, 49 S.E.2d at 355.
For those reasons, it approved an award of custody to the child's mother during the school year and to her father for a portion of the summer. Id. at 274, 49 S.E.2d at 356.
The Court applied its reasoning in Mullen to approve similar results in Andrews v. Geyer, 200 Va. 107, 112-13, 104 S.E.2d 747, 751-52 (1958), Semmes v. Semmes, 201 Va. 117, 124-25, 109 S.E.2d 545, 550 (1959), and Crounse v. Crounse, 207 Va. 524, 532-33, 151 S.E.2d 412, 418 (1966).