A parent is entitled to visitation unless the visits would endanger the child; the endangerment standard is an extraordinary finding that is onerous, stringent, and rigorous and is more stringent than the best interests standard, which is used to determine custody. Pleasant v. Pleasant.
Visitation rights cannot be restricted unless the court finds that the visitation would “endanger seriously the child’s physical, mental, moral or emotional health.”Woods v. Woods.
To restrict visitation rights the trial court must find that the visitation as it exists endangers seriously the child’s physical, mental, moral or emotional health, not merely that a restriction would be in the best interest of the child. In re Solomon.
A prohibition of overnight visitation, a requirement that visitation occur in the custodial parent’s home, or a requirement that visitation occur outside the home of the non-custodial parent if made with children’s best interests in mind and fully supported by the testimony at the hearing is well within the broad measure of discretionary authority given the trial court. Gibson v. Gibson.
The welfare and best interests of the child is the paramount consideration in determining whether visitation rights should be restricted and visitation rights will not be restricted merely because the custodial parent considers such restriction to be advisable. Blazina v. Blazina.
This section does not require a formalistic recital by the trial court that a danger was posed to the child before visitation rights could be restricted, where the trial court’s reasoning for restriction of visitation rights was undeniably and explicitly set forth in the record, and those findings were supported by the evidence. In re Johnson.
Requiring a non-custodial parent to participate in counseling is not a restriction on visitation. In re Fields.
A restriction on a non-custodial parent’s visitation rights is inappropriate absent a finding of serious endangerment. In re Fields.
The custodial parent bears the burden of proving by a preponderance of the evidence that visitation with the non-custodial parent would seriously endanger the child. In re Diehl.
Restriction of visitation rights requires a showing that the visitation endangers the physical of emotional welfare of the child. In re Lewis.
Not every condition which a trial court may place upon a non-custodial parent is a restriction; a restriction of visitation is an action which limits, restrains, or confines visitation within bounds. In re Fields.
The Judge did not err in failing to modify the judgment for dissolution with respect to the provision concerning custody and visitation even though the psychologist examining the
Parties’ daughter, who was solely responsible for establishing a procedure for visitation until relieved of that responsibility by further order of the court, resigned prior to the entry of the judgment and was deceased prior to the hearing. The judge did appoint a doctor to consult with the minor child and each of the parties in order to establish a procedure to reinstate defendant’s visitation, if any, with his daughter. In re Hartian.
Matters of visitation and custody are not to be used as means of punishing either parent. Hock v. Hock.
This statute’s aim is to promote the best interests and welfare of the child, a purpose which generally is served by giving the adopted child the status of a natural child of the adoptive parents and completely breaking all ties with the natural family. Krystek v. Schumacher.
— 
