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County of San Diego v. Madrigal
Anna Martorella appeals a superior court order finding that changed circumstances justified awarding Omar Madrigal sole physical custody of their child. Martorella contends there is insufficient evidence to support the court's changed circumstances finding. In addition, Martorella contends there is sufficient evidence to support the court's determination the custody change was in the best interest of the child. Martorella further contends the court abused its discretion by failing to apply the presumption in Family Code section 3044 that awarding sole physical custody of a child to a parent who has committed domestic violence against the other parent within the previous five years is detrimental to the best interest of the child. Court affirm the order.

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