On a motion and cross-motion to vary a temporary parenting order under the Children’s Law Reform Act, the court found a material change in circumstances based on the moving party’s threatening, coercive and controlling communications, persistent attempts to unilaterally alter parenting terms, and broader evidence of family violence, substance abuse concerns, and dysregulation.
Applying the CLRA best-interests framework, with primary emphasis on the child’s physical, emotional and psychological safety, security and well-being, the court held that unsupervised parenting time was no longer appropriate.
The moving party’s request for expanded parenting time was dismissed, and the responding party obtained an order requiring professionally supervised parenting time, limited in frequency and duration.
The court declined to grant a formal restraining order, but imposed no-attendance and communication restrictions.
