Supervised parenting time

On October 20, 2022, the Michigan Court of Appeals issued its opinion in the case of Krieg v. Krieg after the trial court changed primary custody of the parties minor child to the mother and addressing the issue of supervised parenting time.


The parties married in July 2014. Shortly after the parties married, father began having an extramarital affair with an employee at the pizzeria he owns, in October 2015. In December
2015, Mother and father had discussed starting a family, mother informing her husband that she was was pregnant. Father reacted poorly to this news and mother moved out of the home. The parties divorced in 2016.

After the baby was born, father began visiting the child at mother’s home a few times a week. In September 2016, the trial court entered an Order granting father parenting time in 4 hour increments a few days a week.

The parties submitted to a child custody evaluation, the evaluator recommending the parties receive equal parenting time after a slow transition. Mother reacted negatively to this suggestion and began alienating father from seeing their child.

Testimony from a PhD. and audio recordings supported father’s claims that mother was alienating father. After a hearing, the friend of the court referee recommended that father be awarded primary physical custody of the child and that mother be allowed only supervised parenting time in a therapeutic setting on alternate weekends

The trial court disagreed with the recommendation that mother be awarded supervised parenting time. awarded father primary custody and mother unsupervised parenting time every other weekend. After both parents filed an appeal, the Michigan Court of Appeals upheld the trial court determination and removing the supervised parenting time recommendation.

However, Michigan law provides a legal basis to order supervised parenting time, such as in cases where there is risk of parental alienation, abuse or neglect.

Supervised parenting time – the law.

Michigan Compiled Laws 722.27a governs parenting time and provides that parenting time be granted in the best interest of a child to have a strong relationship with both of his/her parents.

MCL 722.27a(9)(i) provides that a parenting time order may contain reasonable terms or conditions as determined reasonable an appropriate in a particular case. A “reasonable term” can include an Order for supervised parenting time.


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