The issue in this case was whether there was a substantial change in circumstances to warrant a change in physical custody of the children. The Iowa Court of Appeals said yes. Former husband and former wife had a joint physical care arrangement where each parent had the children approximately 50% of the time. Ultimately, the Iowa Court of Appeals held that the level of discord between the two parties and the deterioration of the parent’s ability to co-parent warranted a change in physical custody. The Court modified the joint physical care arrangement awarding former wife primary physical care of the children. It reasoned, among other things, that former husband’s relationship with his live-in girlfriend caused dysfunction in terms of the co-parenting relationship that existed between former husband and former wife. The Court noted that former husband put his live-in girlfriend’s interests above that of his children. In re Marriage of Taylor, No. 15-1003, March 23, 2016.