It is well known that some people often falsely allege assault or other acts of domestic violence in order to remove their spouse or domestic partner from the home or gain sole or primary custody of a child. In the recent custody case of Rex v. Rex, an unreported case decided by the Maryland Court of Special Appeals. A mother filed several meritless order of protection proceedings against the father and took other actions to deny him access to his child. As a result, the trial court held that the mother manipulated the visitation schedule for no sound reason and granted the father primary residential custody during the school year. This decision was upheld by the appellate court.