## Facts

- Steven and Diane Maxfield were married about ten years and had four minor children: Jeremiah (10), Aleshia (8), Therese (4), and Jacinta (2).
- While the family lived together in Verndale, Minnesota, Steven was frequently away for work and trade school, and Diane provided most day-to-day childcare.
- Diane experienced isolation, depression, and poor housekeeping conditions while in Minnesota and sought counseling through county social services.
- In April 1987, at Diane’s request, Steven moved out but continued to spend time with the family on most weekends.
- In June 1987, Diane took the children to Wilkes-Barre, Pennsylvania, initially presented as a visit but with intent to end the marriage and remain there.
- For roughly the year before trial (1988), the children lived with Diane in Pennsylvania; social services in both states conducted evaluations for the custody proceeding.

## Issues

1. Whether the district court misapplied Minnesota’s “best interests of the child” factors by awarding custody to the father despite finding the mother had been the primary caregiver.
2. Whether the primary-caretaker relationship must be given substantial weight within the best-interests analysis, and how that affects custody of the children.

## Decision

- The Supreme Court of Minnesota affirmed the court of appeals.
- Custody of Aleshia, Therese, and Jacinta was awarded to Diane.
- Jeremiah’s custody determination was remanded to the district court for reconsideration under a properly weighted best-interests analysis.

## Legal Principles

- Child custody must be determined under the statutory “best interests of the child” factors.  
- The “primary parent” or primary-caretaker relationship is not a formal presumption, but it is a significant factor that must be given substantial weight when supported by the record.
- A custody analysis is erroneous when it acknowledges a parent’s primary-caretaker role yet fails to account for the resulting bond and continuity-of-care considerations for young children.
- A child’s stated preference is relevant but must be assessed in context, including the child’s age and circumstances.
- Different children in the same family may require different custody outcomes when best-interests factors materially differ (including age, preference, and adjustment).

## Conclusion

The court held that the best-interests framework required substantial weight for the mother’s established primary-caretaker role, supporting custody of the three youngest children with her, while requiring further, child-specific findings on the oldest child before finalizing custody.


Maxfield v. Maxfield, 452 N.W.2d 219 (Minn. 1990)