In the Matter of the Custody of M.j.h. Eric John Christensen v. Danielle Marie Healey

Summary

The court held that Christensen's request to extend alternating-week parenting time from the summer to the entire year was a de facto motion to modify physical custody. Because the proposed change substantially affected Healey's routine daily care and control of the child, the endangerment standard applied rather than the best-interests standard for parenting-time modifications that do not change the child's primary residence. The court therefore reversed the court of appeals.