Custody Battles and Lessons From World War II’s End

On September 2, 1945, the world witnessed the formal surrender of Japan aboard the USS Missouri, marking the end of World War II. The images of that day remind us that even after immense conflict, resolution and new beginnings are possible — but only when there is clarity, structure, and authority guiding the outcome. Much like nations emerging from war, families navigating custody disputes need the framework of law to settle conflicts fairly.

In North Carolina, custody orders can only be modified when there has been a substantial change in circumstances affecting the welfare of the child. This principle, laid out in N.C. Gen. Stat. § 50-13.7, was reaffirmed by the Supreme Court of North Carolina in Shipman v. Shipman, 357 N.C. 471 (2003). In that case, the Court emphasized that not every change justifies a modification; the change must directly impact the best interest of the child. Similarly, Pulliam v. Smith, 348 N.C. 616 (1998) reinforced that the child’s welfare is paramount, and courts will carefully weigh emotional stability, continuity, and the child’s needs before altering custody.

Parents often ask: what qualifies as a substantial change? Relocation (Ludlam v. Miller, 225 N.C. App. 350 (2013)), remarriage, significant changes in a parent’s lifestyle, or deterioration in a child’s performance at school may all qualify. But smaller disagreements — such as disliking a parenting style or minor schedule conflicts — do not rise to this level.

The lesson from September 2, 1945 is that enduring peace requires both sides to accept the rule of law. In child custody, that means accepting that changes cannot be made casually. If you want to modify your order, you must be prepared to show both (1) a substantial change in circumstances and (2) that modification is in the best interest of the child. At Adkins Law, PLLC, we guide parents through this difficult process, ensuring your case is presented with the clarity and strength needed to achieve results. Contact us today.