Ross v. Phillips

SILBERMAN, Judge.

Roxanne Ross (the Mother) challenges the trial court’s visitation orders of February 13, 2004, and June 7, 2004, granting visitation with the parties’ minor child to Robert T. Phillips (the Father). Because the trial court erred as a matter of law in applying the standard for an initial visitation determination rather than the standard for a modification of visitation, we reverse and remand for further proceedings.

The Mother and the Father have one son together, born on May 12, 1995. The Father’s paternity was established in late 1995. An October 16, 1996, Order Amending…