2010 WI App 65, 324 Wis. 2d 820, 783 N.W.2d 874 (WI Ct. App., 2010)
Circuit court lacked the authority under Wis. Stat. §767.451(3) to sua sponte modify the physical placement order. A court cannot modify a placement order in the absence of a petition, motion or order to show cause by a party.
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