Award of third‑party visitation to maternal grandmother on alternating weekends, alternating holidays, and every Christmas Day was more than minimally intrusive of mother’s parental rights and thus impermissibly impinged on her fundamental constitutional right to make decisions concerning care, custody, and control of her child; weekend‑visitation schedule placed child with maternal grandmother nearly twenty percent of the time, not counting the additional holiday time.
Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her website. www.famlawconsult.com