2003 WI App 180, 266 Wis. 2d 534, 669 N.W.2d 175 (2003)
Portion of divorce judgment effecting a prospective change in placement is invalid. Trial court lacks statutory authority to order a change of placement that is prospective and contingent on the occurrence of some anticipated event. Since the subsequent order did not effect placement, the substantial change in circumstances is measured from the date of divorce.
[ Full Opinion ]