Distinguished
Distinguished by Howes v. Howes, 388 So. 2d 1182 (1980)
We conclude the consent judgment on March 9, 1979 is not a "considered judgment" and (3) of Fulco is inapplicable.
Distinguished by Johnson v. Johnson, 1980 La. App. LEXIS 3548 (1980)
The father, on the other hand, contends the heavy burden of the Fulco rule is inapplicable to this situation because the mother had custody by virtue of a consent judgment rather than a “considered decree.
The opinion
SUMMERS, Justice
(dissenting).
I dissent for the reasons assigned by SANDERS, J.