Chickanosky v. Chickanosky, 54 A.3d 162

Mother and father divorced in 2005; they shared parental rights and responsibilities.
In 2009, family court awarded father sole legal parental rights and responsibilities (affirmed).
In July 2010, court granted father’s move to Missouri with father having physical rights; mother retained summertime contact.
Early Aug 2010, mother’s unplanned Missouri visit led to emergency motions; court modified contact but kept some restrictions.
July 2011, after further filings, court issued a 25-page order clarifying/modifying contact, finding mother’s behavior harmful and limiting summertime contact to about one month; decision affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court properly limited summertime contact.	Mother asserts lack of notice and overreach.	Court considered broader contact schedule and changed circumstances.	Yes, court properly limited summertime contact.
Whether there was a real, substantial, unanticipated change in circumstance to modify custody.	Mother contends no sufficient change.	Court found significant, unanticipated changes in conduct and circumstances.	Yes, change in circumstances existed.
Whether the best interests of the child support the limiting of contact.	Limitation not in daughter’s best interests.	Limitation serves daughter’s best interests.	Yes, best interests supported the limitation.
Whether the court properly interpreted the July 2010 order regarding custody and relocation.	Interpretation mischaracterized the order.	Order contemplated transfer to Missouri as in daughter’s best interests.	Court properly interpreted the July 2010 order.

Cleverly v. Cleverly, 151 Vt. 351 (1989) (visitation pattern linked to best interests of child)
DeSantis v. Pegues, 2011 VT 114 (2011) (appellate standard for reviewing best-interests determinations)
P.F. Jurgs & Co. v. O’Brien, 160 Vt. 294 (1993) (change-of-contract interpretation when party argued ambiguity)