Johnson v. Johnson
Annotate this CaseFather and Mother's judgment of divorce incorporated by reference a parenting plan and custody order that gave Mother primary physical custody of the parties' daughter, with Father awarded visitation that required supervision when the child spent the night in Father's custody. At issue was whether the judgment contained an improper self-executing modification that was contingent upon a determination to be made by a person other than a judge. The court held that since the provision regarding the termination of supervision of Father's overnight visitation with his child was a material change in visitation that would occur automatically without judicial scrutiny into the child's best interests, it was an invalid self-executing change of visitation that should not have been included in the judgment and decree of divorce. Accordingly, the court reversed that portion of the judgment and decree of divorce and remanded the case.
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