What findings must support a parent-time modification from supervised to unsupervised? Blocker v. Blocker Explained

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.