holding that the “very normal life change” of “growing up” and becoming involved in activities that conflict with the parenting time schedule, “while insufficient to justify a change in custodial environment are precisely the types of considerations that trial courts should take into account in making determinations regarding modification of parenting time.”
How later courts described this case
- holding that the “very normal life change” of “growing up” and becoming involved in activities that conflict with the parenting time schedule, “while insufficient to justify a change in custodial environment are precisely the types of considerations that trial courts should take into account in making determinations regarding modification of parenting time.”
- explaining that a parenting-time decision only requires findings of fact on contested issues, as opposed to a custody determination, which requires findings on all of the best interest factors
- concluding that “[c]ustody decisions require findings under all of the best-interest factors, but parenting time decisions may be made with findings on only the contested issues”
- holding that the definitions of proper cause and change of circumstances as articulated in Vodvarka apply to custody determinations but not to parenting-time determinations
Written by the judges who cited it.
The opinion
JANSEN, J.
{concurring in the result only). I concur in the result only.