ANIL K. LALL VS. MONISHA SHIVANI

ANIL K. LALL VS. MONISHA SHIVANI

This appeal involves a parent's effort terminate a grandparent's visitation, which had been allowed pursuant to a consent order. We hold that a parent's rights, which the Court recognized in Moriarty v. Bradt, 177 N.J. 84, 114-15 (2003), 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 considered in accordance with the Lepis framework. That is, a parent must make a prima facie showing of changed circumstances as would warrant relief. If the parent vaults that threshold, the parent bears the burden to show the modification or termination would not cause harm to the child.