Trial court did not exceed discretionary authority where it awarded grandmother expansive visitation right. Such order did not violated father’s fundamental liberty rights as father maintained most decision making authority. However, trial court exceeded its authority when it ordered father to obtain psychotherapeutic treatment for child.
Circuit court erred in ordering an injunction to enforce father’s placement during military deployment as physical placement rights are not transferable and cannot be delegated to his new wife. Court also erred in awarding step mother visitation. The trial court did not give deference to mother’s visitation decisions as mandated under Rogers.
Trial court did not misuse its discretion in order visitation for grandparents where their daughter had died. There is not a difference between the quantity of “visitation” and the quantity of “physical placement”. Both are situations where the children go out of the custodial home. No equal protection violation by treating parents with a deceased spouse different from parents in an intact family.