Reynolds v. Reynolds

Respondent appealed from the judgment of the circuit court granting a directed finding in favor of the petitioner on respondent’s amended motion to modify the allocation of parental responsibilities and parenting time. Respondent argued that the trial court erred by applying the wrong legal standard to his request for increased parenting time. The appellate court vacated and remanded, holding that a party seeking to solely modify parenting time need only to show a simple change in circumstances and not a substantial change in circumstances. (SCHOSTOK, concurring and BIRKETT, dissenting)