Marriage of Rose v. Rose


2017 WI App 7, 2015AP2646 and 2016AP692 (WI Ct. App., 2016)


Trial court does not have authority to change placement within two years of the initial placement order, absent finding of harm, if the modification would substantially alter the time a parent spends with the child.  Trial court reversed for changing placement time with father, even though the order did not change primary placement, because it substantially altered the father’s time with the child.

[ Full Opinion ]