In a Decision – Bocelle v. Caldwell (an "Unreported Decision") >> the Court Held:
The Appellate Division disagreed with the Trial Court’s Decision to Change Custody of Grandparents without first determining that a Change of Circumstances where there had been a previous establishment of Custody.
Allegations on both sides of hurtful and harassing conduct were presented. The Trial Court entered an order declaring grandparenting time to be at the discretion of Parents and that Grandparents had not made a sufficient showing of harm to the child to mandate guaranteed Grandparent Visitation. The Appellate Division determined that inasmuch as the parties entered into a consent order allowing the grandparent visitation, a request to modify such order must be supported by a prima facie showing of changed circumstances.
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