That was the central question in this case. Grandfather had been getting extensive visitation with his minor grandson. Mother decides to lessen the visitation. Grandfather files a motion with the court requesting that he continue to get extensive visitation with his grandson, and arguing that anything less would be harmful to their relationship. The trial court found that merely lessening the amount of visitation was not going to be harmful to the child. Had the visitation been stopped entirely then that would likely be harmful to the child. The Court of Appeals affirmed the decision.

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Hollingsworth v. Hollingsworth