Jessica K. Lagatta v. Brandon B. Kettler, 21-0418

Parties divorced in Kansas (2016) with a stipulated parenting plan: joint legal custody, Jessica primary physical custodian, Brandon on supervised-to-unsupervised alternating-weekend visitation; Brandon initially required to provide children's health insurance and submit to drug/mental-health monitoring for limited periods.
Both parents later moved to Iowa; Brandon registered the Kansas decree and petitioned in Iowa to modify visitation and other terms.
Trial evidence showed Brandon has ongoing mental-health disorders and chronic pain treated with multiple prescriptions; he refused voluntary hair testing but a court-ordered hair test during the modification proceeding was positive for cannabinoids; other court-ordered and medical urinalyses were otherwise negative.
The district court denied Brandon’s request to increase visitation, shifted responsibility for the children’s health insurance to Jessica, extended and clarified drug-testing and mental-health reporting requirements, and authorized Jessica to suspend Brandon’s parenting time upon a positive hair test for a specified period.
On appeal the Iowa Court of Appeals affirmed the modification order largely as entered, but shortened the automatic suspension period after a positive hair test from three months back to two months (reinstatement after two consecutive negative monthly tests); appellate attorney-fee requests were denied for both parties.

Issue	Brandon's Argument	Jessica's Argument	Held
Increase visitation	Brandon sought more overnight time (additional weekend night).	Jessica opposed, citing children’s best interests and Brandon’s ongoing issues.	Denied—no change in circumstances justified increased visitation.
Who provides children’s health insurance	Brandon argued he should remain responsible.	Jessica sought designation as insurer because her coverage is adequate and less costly; insurance procurement had been a source of conflict.	Modified—Jessica to provide insurance (substantial change in circumstances).
Terminate drug tests and mental-health reporting after set period	Brandon argued requirements should end after prior year of compliance.	Jessica argued ongoing monitoring remains necessary for children’s safety.	Denied—court affirmed indefinite monitoring (monthly hair tests on request and quarterly mental-health reports) until future modification upon demonstrable improvement.
Must Jessica obtain court approval before suspending visitation after positive drug test?	Brandon argued suspensions should require prior court approval.	Jessica relied on decree language allowing immediate suspension upon objective positive test.	Mostly affirmed—court upheld immediate suspension on objective positive hair test but modified suspension length to two months with reinstatement after two consecutive negative monthly tests.

In re Marriage of Harris, 877 N.W.2d 434 (Iowa 2016) (standard of review for modification in equity is de novo)
In re Marriage of Brown, 778 N.W.2d 47 (Iowa Ct. App. 2009) (substantial change required to modify custody; less required for visitation)
Nicolou v. Clements, 516 N.W.2d 905 (Iowa Ct. App. 1994) (a substantial change is not always necessary to modify visitation)
In re Marriage of Salmon, 519 N.W.2d 94 (Iowa Ct. App. 1994) (burden on party seeking visitation modification: material change + best interests)
Lamansky v. Lamansky, 207 N.W.2d 768 (Iowa 1973) (courts must set visitation terms; cannot leave discretionary control to a parent)
Willey v. Willey, 115 N.W.2d 833 (Iowa 1962) (decrees cannot vest unilateral visitation discretion in a parent)
In re Marriage of Goodman, 690 N.W.2d 279 (Iowa 2004) (children’s health insurance is part of child support and may be modified)
In re Marriage of Mihm, 842 N.W.2d 378 (Iowa 2014) (child-support provisions, including insurance, modifiable upon substantial change)
In re Marriage of Okland, 699 N.W.2d 260 (Iowa 2005) (appellate attorney fees in dissolution matters are discretionary)