Hill v. Fox

Summary

The Court affirmed the Family Court’s order modifying Father’s visitation and declining to hold Mother in contempt. It held that the heightened statutory endangerment standard, rather than a standalone best-interests analysis, governed the requested modification because the prior order was entered after a merits hearing less than two years earlier and the requested change would substantially restrict Father’s contact. The Court also upheld the denial of recusal and found sufficient evidence supporting therapeutic visitation and the contempt ruling.