Utah Court of Appeals
What findings must support a parent-time modification from supervised to unsupervised? Blocker v. Blocker Explained
Summary
Following remand for inadequate findings, the district court entered detailed findings supporting its decision to grant mother unsupervised parent-time with her teenage son. The court found changed circumstances including successful therapy, incident-free supervised visits, and the child’s increased maturity, concluding unsupervised parent-time would best foster the mother-child relationship.
Analysis
The Utah Court of Appeals in Blocker v. Blocker provides important guidance on the factual findings required when a district court modifies parent-time arrangements from supervised to unsupervised status.
Background and Facts
Following the parents’ divorce, the district court initially granted the mother supervised parent-time due to concerns about her behavior’s impact on the child. The court later temporarily granted unsupervised parent-time based on a home study report, then made it permanent without entering findings of fact. On appeal, the Utah Court of Appeals remanded for adequate findings supporting the modification.
Key Legal Issues
The case addressed two critical questions: whether the district court properly identified changed circumstances sufficient to support parent-time modification, and whether the court conducted an adequate best interest analysis when eliminating supervised parent-time requirements.
Court’s Analysis and Holding
The court applied the abuse of discretion standard and confirmed that parent-time modification requires a two-step process. First, the petitioner must show “some” change in circumstances—a lower threshold than the substantial change required for custody modifications. Second, the court must consider whether modification serves the child’s best interests. The court found adequate changed circumstances, including the mother’s continued therapy, incident-free supervised visits, the child’s increased maturity, and the practical unenforceability of the original supervision requirements due to cost and unavailable services.
Practice Implications
This decision emphasizes that district courts must enter sufficiently detailed findings that disclose the analytical steps leading to parent-time modifications. The findings must address both changed circumstances and best interest considerations. Courts have broad discretion in parent-time matters, but that discretion must be exercised based on adequate factual development that facilitates meaningful appellate review.
Case Details
Case Name
Blocker v. Blocker
Citation
2019 UT App 82
Court
Utah Court of Appeals
Case Number
No. 20170167-CA
Date Decided
May 16, 2019
Outcome
Affirmed
Holding
A district court’s modification of supervised parent-time to unsupervised parent-time will be upheld when supported by adequate findings showing changed circumstances and that the modification serves the child’s best interests.
Standard of Review
Abuse of discretion for district court’s parent-time decisions
Practice Tip
When seeking to modify parent-time arrangements, ensure detailed findings address both changed circumstances and the child’s best interests, as inadequate findings will result in remand for proper factual development.
Need Appellate Counsel?
Lotus Appellate Law handles appeals before the Utah Court of Appeals, Utah Supreme Court, California Court of Appeal, and the United States Court of Appeals for the Tenth Circuit.
Related Court Opinions
About these Decision Summaries
Lotus Appellate Law publishes these summaries to keep practitioners informed — not as legal advice. Each case turns on its own facts. If a decision here is relevant to your matter, we’re happy to discuss it.