David and Rita Foreng were married December 7, 1985. They had two children during their marriage, one with cerebral palsy who requires a brace and medication. David and Rita separated in September 1991, and David initiated this divorce action in December 1991. The trial court awarded physical custody of the two children to Rita. Trial courts must make custody determinations according to the best interests and welfare of the child.
Trial courts have substantial discretion in determining a child's best interests.
E.g. , Freed , supra . We treat a trial court's custody determinations as findings of fact and review them under a clearly erroneous standard. A finding of fact is clearly erroneous when no evidence exists to support it or the reviewing court, on the entire evidence, has a definite and firm conviction that the trial court made a mistake. David alleges numerous errors in the court's custody determination. He argues that the trial court clearly erred in finding that Rita's extramarital relationship did not have a negative effect on the children, that Rita adequately met the disabled child's special needs, that Rita provided a more comfortable home environment for the children, and that Rita's parenting skills were adequate, and in adopting the findings of a home study which recommended that the court award custody to Rita.