Alaska Supreme Court
Susan M., Appellant v. Paul H., Appellee
December 11, 20152015 Alas. LEXIS 151
Summary
The Alaska Supreme Court affirmed the superior court’s denial of Susan M.’s motions for sanctions, make‑up visitation, an injunction to block Paul H.’s relocation, and a modification of custody. The Court held that Paul acted with a just excuse in denying visitation, that no substantial change in circumstances justified a custody modification, and that the superior court was not required to conduct a best‑interests analysis. The decision emphasizes that unilateral suspension of visitation is improper except in exceptional cases.