Where the adulterous relationship of petitioners was practically the only factor considered in making an award of custody, and that adulterous relationship had terminated, a more meaningful inquiry would be made into the best interests of the minor child with regard to placement of her custody.  In re Combs
 Where the flagrant adulterous relationship between the custodial mother and a married man did affect the relationship of mother and children and negatively affected the moral health of children, the trial court did not err or abuse its discretion in transferring custody of the minor children to their father, despite the mother’s remorse over her actions.  De Franco v. De Franco
 Where the trial court found against defendant on his counterclaim which alleged plaintiff’s adultery as ground for divorce, the court did not err in awarding custody to plaintiff.  Fields v. Fields
 Fact that a divorce has been awarded to a husband on the grounds that the wife was guilty of adultery does not prevent the trial court from exercising its discretion and awarding custody of the children to the wife.  Huey v. Huey
 Plaintiff’s adultery was a reflection on her moral values; the moral climate in which children are to be raised in a valid consideration for the court to evaluate.  Mulvihill v. Mulvihill
 Where a mother had exposed her children to immoral behavior by living with one married man in the home occupied by herself and children, by residing with another married man in a home visited by the children, and had pleaded guilty to a crime involving moral turpitude, the court’s decision that the children should remain with the father could have been sustained either on the basis of her unfitness or on the basis of her failure to prove a change in circumstances.  Filipello v. Filipello

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