In a Decision – Gatto v. Breton, . (an "Unreported Decision") >> the Court Held:
The Appellate Division reversed the Decision of the Trial Court to require a custody evaluation as there has not been a demonstration of a change of circumstances.
The appellate court remarked that a custody evaluation was a very expensive and intrusive investigation into all aspects of the parties' lives and the best interests of the children. The appellate court found that ordering defendant to cooperate in a custody evaluation was only permitted following a prima facie showing of changed circumstances.