John E. and Sally E., a Minor v. Andrea E.

Summary

The court vacated the custody decision because the superior court improperly excluded relevant psychologist testimony as a sanction for the father's violation of the mother's sole legal custody authority. It held that the mother's assault did not trigger the statutory domestic-violence custody presumption because it caused no serious physical injury and constituted only one incident, but it identified inadequate explanation of the father's restricted visitation and upheld the protective order. The court also held that the father waived his challenge to denial of his motion to suspend the mother's visitation.