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181 Wis.2d 304, 510 N.W.2d 775 (Ct. App. 1993)
Summary
Modification within 2 yrs. requires proof on necessity, that custodial conditions are harmful and physical or emotional harm is severe enough to warrant modification. “Necessary” is more that best interests, but less than essential. No need to prove child has actually suffered harm, but that severity of harm threatened is high enough that modification is necessary. Here, evidence of mother’s interference with placement with father is not sufficient, as other remedies are available.
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