Where a child, during her in camera testimony, stated that she loved both her parents and did not want to hurt either of them by choosing the other; nevertheless, she felt more comfortable living with her mother, with whom she could talk more freely, the trial court did not abuse its discretion in granting custody of the child to her mother.  In re Seymour
 It was not an abuse of discretion to award custody of 15 year old daughter to husband, where he testified that daughter told him she does not want to make a decision ‘because she feels guilty leaving her mother,” and where doctor’s report observed that daughter was “the most conflicted and anxious emotionally” of the three children because she felt she might be happier with her dad, but would feel too guilty about leaving her mother, and her stated preference to the court that she live with her mother was based on guilt and fear that something would happen to her mother if she was not there; the court was not precluded from finding that the child’s preference was not in the child’s best interest.  In re Leff
 Where a trial court considered all the relevant factors and found that an award of custody to the natural father was in the best interests of the child, this finding was supported by the evidence and was not an abuse of discretion.  In re Krause
Divorce Lawyers San Antonio

 In order to justify a change in child custody, a material change of circumstance which affects the welfare of the child must be shown, and the party seeking the change in custody has the burde  of proving that the child’s best interests warrants the change.  Sorenson v. Sorenson
 To justify a change in custody, the evidence must establish that the parent to whom the children were last awarded is unfit to retain custody or that a change of circumstances makes a change of custody in the children’s best interest.  Filipello v. Filipello
 It is not necessary for the validity of an order changing custody to another parent that the evidence of new facts establish the present unfitness of the parent to whom custody has been previously entrusted if other circumstances are clearly shown which require a modification for the welfare of the children.  Kline v. Kline
 If provisions of a custody disposition are to be changed, the burden of proof is on the party so moving to show why it should be done.  Martinec v. Sharapata

  Illinois courts appear reluctant to find the child has been with the non-parent for a “substantial” period of time if the non0parent had physical custody only for several months.  In re Cannon.
 Aunt and uncle had to show that child was not in the physical custody of a parent at the time they sought custody under subdivision (b)(2) and subsection (c) of this section.  In re Nicholas.
 Where the petitioner was a nurse’s aide at a state founding home in Riga Latvia, where the child was taken shortly after her birth, and as an employee of this institution took care of the minor, left the home with the child as a result of an evacuation of refugees and because her godmother, however laudable as a work of mercy, it did not vest her with any legal rights to the child’s custody; the petitioner was not one in loco parentis and did not have to be made a party defendant in adoption proceedings or be given notice thereof.  Klabis v. Hoyer.

Link