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In re Marriage of Hadeen

Court of Appeals of Washington
619 P.2d 374 (Wash. App. 1980)


Facts

Judith Hadeen (plaintiff) petitioned for divorce from Glen Hadeen (defendant) and sought custody of their five minor children. At a hearing, the evidence showed that Judith followed the religious teachings of a Christian sect (the Church) that emphasized a strict code of discipline as a means of controlling children. Consequently, Judith sometimes employed spanking, isolation, and other harsh techniques as a means of discipline. Glen, a former member of the Church, testified that the Church’s members were taught not to associate with nonbelievers. After speaking with the children in the judge’s chambers and reviewing a report submitted by a court-appointed psychiatrist who had evaluated the children’s well-being, the trial court concluded that Judith provided proper care to the children, who were well-adjusted and maintained strong bonds with both parents, but that Judith strictly followed the mandates of the Church even to the detriment of other relationships. Further, the trial court acknowledged but disregarded the psychiatrist’s recommendation that the children’s custody be with Judith so long as the issues caused by her affiliation with the Church were remedied. The trial court awarded custody of the oldest child to Judith and custody of the remaining four children to Glen. Judith appealed.

Rule of Law

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Issue

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Holding and Reasoning (Callow, C.J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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