In re the Marriage of Nicholas Jay Dale and Nicole Jehlicka Dale., Respondent:

Summary

The court held that a purely quantitative reduction in parenting time remains a modification, regardless of its size, unless it eliminates parenting time altogether. A restriction occurs only when parenting time is reduced to zero or subjected to qualitative constraints on its manner, location, or environment, and only restrictions require the endangerment-or-emotional-impairment standard. Because the district court reduced Father's parenting time without eliminating it or imposing qualitative constraints, it properly applied the best-interests standard, so the court affirmed and remanded with instructions.