2005 WI App 212, 287 Wis. 2d 472, 704 N.W.2d 916 (2005)
Father did not waive his right to object to wife’s parenting plan when he failed to submit his own plan prior to the scheduling conference. Even if there was waiver, the paramount concern in placement and custody decisions is the best interests of the child. Although the court may consider a party’s uncooperative behavior, it must clearly articulate how that bears on best interests.
[ Full Opinion ]