Often, the decision of which parent a child should live with after a divorce is an extremely difficult decision for a court to reach. After all, no one can know the true dynamics of a family unless they live it. Sometimes, even the court’s decision is not always permanent. In Skinner v. Cole, App. Div, the court determined that custody should be changed from mother to father. Plaintiff-mother appealed the order that transferred physical custody of the parties' son, then 13-years-old, to defendant-father. This was largely because the trial court failed to hold a plenary hearing to resolve the disputed issues of material fact that were apparent from the parties' conflicting Certifications before transferring custody. The Appellate Court vacated the trial court's order and remanded for further proceedings.