Callender v. Skiles

623 N.W.2d 852 (Iowa 2001) · Supreme Court of Iowa · March 21, 2001 · No. No. 00-0069

Summary

The Iowa Supreme Court reviewed visitation awarded to a biological father after paternity was established and the established father's parental relationship was disestablished. The court upheld the visitation schedule under a best-interest-of-the-child analysis, including consideration of Iowa Code sections 600B.41A and 598.41. It modified the order requiring the child to be told of her biological parentage by leaving that decision to the custodial mother.

Holdings

  1. A court determining visitation under Iowa Code section 600B.41A(6)(a)(2)'s best-interest standard may consider the maximum-continuing-contact principle in section 598.41, along with other established visitation principles and relevant case-specific factors; section 600B.41A's listed factors are not exclusive.
  2. The district court should not have ordered a specific timeline for telling Samantha of her parentage; the decision was left to Rebecca Skiles as the sole custodial parent.

Questions Presented

  1. Whether the district court improperly considered Iowa Code section 598.41's maximum-contact principle when determining visitation under Iowa Code section 600B.41A(6)(a)(2).
  2. Whether the district court had authority to order when Samantha must be told that Callender is her biological father.

Disposition

other

Cases Cited (7)

  • Callender v. Skiles, 591 N.W.2d 182 (Iowa 1999)(followed)
  • In re Marriage of Forbes, 570 N.W.2d 757, 759 (Iowa 1997)(followed)
  • Dye v. Geiger, 554 N.W.2d 538, 539 (Iowa 1996)(followed)
  • In re Marriage of Weidner, 338 N.W.2d 351, 356 (Iowa 1983)(followed)
  • Olds v. Olds, 356 N.W.2d 571, 574 (Iowa 1984)(followed)
  • In re Marriage of Littlefield, 133 Wash. 2d 39, 940 P.2d 1362, 1371 (1997)(followed by analogy)
  • Chant v. Chant, 725 So. 2d 445, 448 (Fla. Dist. Ct. App. 1999)(followed by analogy)

Cited In (0)

No citing cases on record yet.

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