adequate cause requirement in Washington

2019“The primary purpose of the threshold adequate cause requirement is to prevent movants from harassing nonmovants by obtaining a useless hearing.” In re Marriage of Adler, 131 Wn.

2017"The primary purpose of the threshold adequate cause requirement is to prevent movants from harassing nonmovants by obtaining a useless hearing." In re Marriage of Adler, 131 Wn.

2019App. 717, 724 , 129 P.3d 293 (2006).

2017App. 717, 724 , 129 P.3d 293 (2006).

2017We have repeatedly stated that a nonparent petitioner will be able to demonstrate adequate cause only in “ ‘extraordinary circumstances.’ ” 179 Wn.2d at 236 (internal quotation marks omitted) (quoting Shields, 157 Wn.2d at 145 ).

2017We have repeatedly stated that a nonparent petitioner will be able to demonstrate adequate cause only in '"extraordinary circumstances."' B.MH, 179 Wn.2d at 236 (internal quotation marks omitted) (quoting Shields, 157 Wn.2d at 145 ).

2003Considering the strong policy favoring custodial continuity and against disrupting children with modification, In re Marriage of Pape, 139 Wn.2d 694, 709 , 989 P.2d 1120 (1999), neglect in supporting a motion for modification with available evidence should rarely be justified as excusable.

2003Considering the strong policy favoring custodial continuity and against disrupting children with modification, In re Marriage of Pape, 139 Wash.2d 694, 709 , 989 P.2d 1120 (1999), neglect in supporting a motion for modification with available evidence should rarely be justified as excusable.

2003Considering the strong policy favoring custodial continuity and against disrupting children with modification, In re Marriage of Pape, 139 Wn.2d 694, 709 , 989 P.2d 1120 (1999), neglect in supporting a motion for modification with available evidence should rarely be justified as excusable.

2003Considering the strong policy favoring custodial continuity and against disrupting children with modification, In re Marriage of Pape, 139 Wash.2d 694, 709 , 989 P.2d 1120 (1999), neglect in supporting a motion for modification with available evidence should rarely be justified as excusable.

2026Opening Br. of Appellant at 39 (citing Mathews v. Eldridge, 424 U.S. 319 , 96 S. Ct. 893 , 47 L.

2026Opening Br. of Appellant at 39 (citing Mathews v. Eldridge, 424 U.S. 319 , 96 S. Ct. 893 , 47 L.

2025Cf. In re Marriage of Ambrose, 67 Wn.

2025App. 343, 349 , 22 P.3d 1280 (2001) (“Because of the trial court’s unique opportunity to observe the parties, the appellate court should be ‘extremely reluctant to disturb child placement dispositions.’” (quoting In re Marriage of Schneider, 82 Wn.

2025Id.

2025App. 343, 349 , 22 P.3d 1280 (2001) (“Because of the trial court’s unique opportunity to observe the parties, the appellate court should be ‘extremely reluctant to disturb child placement dispositions.’” (quoting In re Marriage of Schneider, 82 Wn.

2025We cannot say that the trial court, which had a unique opportunity to observe these parties, both of whom are attorneys who represented themselves pro se at the adequate cause hearing, erred when it found that Hoag failed to demonstrate adequate cause as to the requirement in RCW 26.09.260(2)(c) that he show the children’s present environment is detrimental. 3 Cf. In re Parentage of Schroeder, 106 Wn.

2024Bower, 89 Wn.

2018In re Marriage of Short, 125 Wn.2d 865, 868-69 , 890 P.2d 12 (1995) (childless couple disputing unique terms in a spousal maintenance agreement); In re Marriage of Lee, 176 Wn.

2018In re Marriage of Short, 125 Wn.2d 865, 868-69 , 890 P.2d 12 (1995) (childless couple disputing unique terms in a spousal maintenance agreement); In re Marriage of Lee, 176 Wn.

2018“The primary purpose of the threshold adequate cause requirement is to prevent a useless hearing.” Grieco, 144 Wn.

2018In re Marriage of Short, 125 Wn.2d 865, 868-69 , 890 P.2d 12 (1995) (childless couple disputing unique terms in a spousal maintenance agreement); In re Marriage of Lee, 176 Wn.

2017In re Custody of E.A.T.W., 168 Wn.2d 335, 348 , 227 P.3d 1284 (2010).

2017In re Custody of E.A.T.W., 168 Wn.2d 335, 348 , 227 P.3d 1284 (2010).

2014The trial court will allow a hearing on the motion only if the affidavit establishes adequate cause.4 "The primary purpose of the threshold adequate cause requirement is to prevent movants from harassing nonmovants by obtaining a useless hearing."5 Adequate cause requires something more than prima facie allegations that, if proven, would permit a court to modify the parenting plan.6 At a minimum, adequate cause 2Stern, 57 Wn.

2014App. 265, 270 , 272 P.3d 908 , review denied. 175Wn.2d 1008(2012). 4 No. 70025-1-1/5 independent findings and conclusions, the order on revision supersedes the commissioner's ruling.5 A trial court's adequate cause determination under RCW 26.09.270 will not be reversed absent an abuse of discretion.6 Discretion is abused if the court's decision is manifestly unreasonable or based on untenable grounds or untenable reasons.7 "The primary purpose of the threshold adequate cause requirement is to o prevent movants from harassing nonmovants by obtaining a useless hearing." At a minimum, adequate ca

2014App. 854, 863 , 250 P.3d 1072 (2011); In re Marriage of Dodd. 120 Wn.

2014App. 854, 863 , 250 P.3d 1072 (2011); In re Marriage of Dodd. 120 Wn.

2014App. at 712 . 3 In re Marriage of Ziqler, 154 Wn.

2014App. 265, 270 , 272 P.3d 908 , review denied. 175Wn.2d 1008(2012). 4 No. 70025-1-1/5 independent findings and conclusions, the order on revision supersedes the commissioner's ruling.5 A trial court's adequate cause determination under RCW 26.09.270 will not be reversed absent an abuse of discretion.6 Discretion is abused if the court's decision is manifestly unreasonable or based on untenable grounds or untenable reasons.7 "The primary purpose of the threshold adequate cause requirement is to o prevent movants from harassing nonmovants by obtaining a useless hearing." At a minimum, adequate ca

2012In re Marriage of Shryock, 76 Wn.