R. H. v. M. H.

Summary

The court held that the trial court improperly delegated judicial authority by allowing the custodial father, after consulting the child's therapist, to suspend or terminate the mother's established visitation rights. Although trial courts retain broad discretion to structure visitation and may authorize reasonable scheduling changes or protective conditions, they may not transfer to a custodial parent the authority to decide whether the other parent may visit at all. Chief Justice Robinson, joined by Justice Mullins, concurred in the judgment but would have permitted narrowly limited cancellation of individual visits when necessary to protect a child from demonstrated risks of harm.