K.J.R. v. M.A.B.Annotate this Case
Child had contact with his paternal grandparents even after Mother married Stepfather. Later, Stepfather initiated a step-parent adoption of Child, and Mother curtailed the grandparent visits. Child's biological father (Father) contested the adoption, and Grandfather intervened in the proceedings to petition for a grandparent visitation order. The trial court granted Stepfather's adoption petition and granted Grandfather limited visitation of Child. The order also imposed no restrictions on Father's contact with Child. Mother appealed the visitation order. The Supreme Court remanded for new findings and conclusions, holding that the trial court's grandparent-visitation order was defective because it failed to (1) include findings that addressed four factors for balancing the parents' rights and the child's best interests and (2) limit the visitation award to an amount that did not substantially infringe on the parents' rights to control the upbringing of their children.