In re Marriage of Royer

Petitioner appealed from a trial court judgment granting overnight parenting time to the respondent, arguing that the trial court’s modification of the parenting plan was not in the minor’s best interests and that it was not a minor modification. The appellate court reversed, finding that increasing the number of overnight visits from zero to 26 was not a “minor modification” and that the trial court’s finding to the contrary was manifestly erroneous. (KENNEDY and JORGENSEN, concurring)