In a Decision – Slawinski v. Nicholas (a "Reported Decision") >> the Court Held:
If the Court ordered Grandparent Visitation, then a Court must alter the ordered Grandparent Visitation and then upon a Change in Circumstances.
The parent's effort terminate a grandparent's visitation, which had been allowed pursuant to a consent order do not empower a parent to terminate or modify a consent order unilaterally. Rather, a request to modify or terminate visitation by consent order must be based upon a showing of changed circumstances as would warrant relief. Then, the parent bears the burden to show the modification or termination would not cause harm to the child.