167 Wis.2d 315, 481 N.W.2d 672 (Ct. App., 1992)
Since modification was within two years of initial order, trial court erred by focusing on best interests of child instead of necessary-to-modify standard. During the two year adjustment period, interference by the custodial parent which does not make removal necessary must be corrected by mediation or contempt – not by modification of custody.
[ Full Opinion ]