fully flourish and develop. 128 They are constantly moving from one home to another, 129 adapting
from one set of rules to another, and adjusting from one routine back to another. 130 Though they
need to feel safe and secure, the children in these cases lack the consistent structure that is
necessary to feel that they truly belong in either environment. 131 They essentially feel like they
have two lives, as they wander from one place to another. 132 Moreover, the instability and
inconsistent values impact the child’s distinctions between right and wrong, good and bad, and
appropriate and inappropriate. This lack of stability and increased potential for conflict between
the parents is detrimental to the development and growth of a child. 133 Joint custody promotes
fairness among the parents at the expense of the children involved, who must grow up in a world
where the only foreseeable surroundings are inconsistency, chaos, and utter confusion. 134
Joint custody creates an arrangement that cannot endure inevitable yet unavoidable,
unpredictable life changes. Certainly, children in joint custody arrangements will most likely be
placed in the difficult situation of moving from two homes into ultimately one primary house. 135
Parents’ lives change with time. They move for jobs or new relationships. They often times
remarry or cohabitate with a new partner. 136 These life changes may be a major reason why
shared custody arrangements typically do not last. 137 Because these life alterations often clash
with joint custody arrangements, many children are eventually forced to give up a home and
128 See Scott & Derdeyn, supra note 110, at 494-95.
129 See Hardcastle, supra note 107, at 201; See JANA B. SINGER & WILLIAM L. REYNOLDS, A Dissent on Joint
Custody, 47 MD. L. REV. 497, 509 (1988).
130 See Scott & Derdeyn, supra note 110, at 485-86.
131 See SINGER & REYNOLDS, supra note 123, at 510.
132 Scott & Derdeyn, supra note 110, at 486.
133 ELROD & DALE, supra note 93, at 388.
136 Most people remarry after divorce. See Rose M. Kreider, Remarriage in the United States, U.S. CENSUS BUREAU
(August 10, 2006), https://www.census.gov/hhes/socdemo/marriage/data/sipp/us-remarriage-poster.pdf.
