2005 WI App 58, 280 Wis. 2d 405, 694 N.W.2d 503 (2005)
Trial court erroneously exercised it discretion where it does not refer to statutory factors, but was largely based on its belief that the temporary schedule was working and the recommendation of the GAL. The trial court cannot rely on GAL statements which are not in evidence. Proof of a material change in circumstances is not necessary to warrant a different custodial (or placement) determination than the one ordered at a temporary hearing.
[ Full Opinion ]