modification hearing in Washington

2025App. 9, 14 , 964 P.2d 359 (1997); RCW 26.09.270.

2024App. 9, 14 , 964 P.2d 359 (1997); RCW 26.09.270.

2025Furthermore, before Hoag was entitled to a full modification hearing, he needed to “demonstrate that ‘adequate cause’ exist[ed] to modify the permanent parenting plan.” Bower v. Reich, 89 Wn.

2024Generally, before a petitioner is entitled to a full modification hearing, “he or she must first demonstrate that ‘adequate cause’ exists to modify the permanent -4- No. 85074-1-I parenting plan.” Bower v. Reich, 89 Wn.

2014The Brown court wrote: The Petrich rule was a modification of a rule first announced in State v. Osborne, 39 Wash. 548 , 81 P. 1096 (1905), and later explained in State v. Workman, 66 Wash. 292 , 119 P. 751 (1911).

2014The Brown court wrote: The Petrich rule was a modification of a rule first announced in State v. Osborne, 39 Wash. 548 , 81 P. 1096 (1905), and later explained in State v. Workman, 66 Wash. 292 , 119 P. 751 (1911).

2014The Brown court wrote: The Petrich rule was a modification of a rule first announced in State v. Osborne, 39 Wash. 548 , 81 P. 1096 (1905), and later explained in State v. Workman, 66 Wash. 292 , 119 P. 751 (1911).

2014The Brown court wrote: The Petrich rule was a modification of a rule first announced in State v. Osborne, 39 Wash. 548 , 81 P. 1096 (1905), and later explained in State v. Workman, 66 Wash. 292 , 119 P. 751 (1911).

2013App. 536, 541-42 , 85 P.3d 966 (2004) (holding that a court does not have discretion to grant a modification hearing if there is no adequate cause shown); In re Marriage of Shryock, 76 Wn.

2013App. 536, 541-42 , 85 P.3d 966 (2004) (holding that a court does not have discretion to grant a modification hearing if there is no adequate cause shown); In re Marriage of Shryock, 76 Wn.

2013Standard of Review ¶9 “We review questions of statutory interpretation de novo.” State v. Morales, 173 Wn.2d 560 , 567 n.3, 269 P.3d 263 (2012).

2013Standard of Review ¶9 “We review questions of statutory interpretation de novo.” State v. Morales, 173 Wn.2d 560 , 567 n.3, 269 P.3d 263 (2012).

2013App. 536, 541-42 , 85 P.3d 966 (2004) (holding that a court does not have discretion to grant a modification hearing if there is no adequate cause shown); In re Marriage of Shryock, 76 Wn.

2013App. 536, 541-42 , 85 P.3d 966 (2004) (holding that a court does not have discretion to grant a modification hearing if there is no adequate cause shown); In re Marriage of Shryock, 76 Wn.

2004Under Morrissey , a defendant has “the right to confront and cross-examine adverse witnesses (unless the hearing officer specifically finds good cause for not allowing confrontation).” Morrissey, 408 U.S. at 489 .

2004Under Morrissey , a defendant has "the right to confront and cross-examine adverse witnesses (unless the hearing officer specifically finds good cause for not allowing confrontation)." Morrissey, 408 U.S. at 489 , 92 S.Ct. 2593 .

2020Because we hold that the modification standard in RCW 26.10.190(1) is unconstitutional as applied to nonparental custody orders, we do not reach this argument. 5 No. 52283-7-II Wn.2d 126, 150, 136 P.3d 117 (2006).

2018App. 741, 749 , 247 P.3d 444 (2011)). 3 No. 77407-7-1/4 a court has discretion when deciding whether adequate cause exists to hold a modification hearing.10 A court abuses its discretion if its decision is “based on untenable grounds or untenable reasons.”11 I.

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.

2018She asserts that if a relocating parent with a 50/50 residential schedule cannot prove a basis for a major modification, the parent will be prevented from relocating,"because she is bound to a parenting plan that places the child equally in each parent's home regardless of the distance." She relies on In re Marriage of Momb, 132 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.

2017App. 422, 427 , 333 P.3d 534 (2014); RAP 2.5(a)(3). -4- No. 75466-1-1/5 Incomplete Evidence Dana contends the trial court erred in conducting the modification hearing without having all of the evidence before it.

2015Id. (issue two).

1998In re Marriage of Murphy, 48 Wn.

1986App. 815, 816-17 , 677 P.2d 789 (1984), this court held that, under Gimlett, there was a sufficient basis for a trial court's modification of a divorce decree to allow post-minority support for higher education where "the parties could not have predicted that [the children] would have . . . qualified for post-high school education [at a previous modification hearing]." The Studebaker court noted that there had been a substantial change of condi *845 tions not contemplated by the parties since, at the time of the previous modification hearing, one child was having substantial difficulties at sc

1975RCW 26.16.205; Lane v. Lane, supra at 634; Hinson v. Hinson, 1 Wn.

1975Lambert v. Lambert, 66 Wn.2d 503, 509 , 403 P.2d 664 (1965); Corson v. Corson, supra at 615.

1975Lambert v. Lambert, 66 Wn.2d 503, 509 , 403 P.2d 664 (1965); Corson v. Corson, supra at 615.

1962Our adoption of the Missouri rule as stated in Hines v. Continental Baking Co., supra, constitutes a modification of the doctrine of assumption of risk in this state.

1933The modification of the rule stated in the case of In re Field’s Estate, supra, is tersely expressed in Tracy v. Barton, 139 Wash. 440 , 247 Pac. 734 , in the following language: “We have held that, when no time for the performance of a contract is fixed by the parties, if it nevertheless appears from the surrounding circumstances and, considering the object contemplated by the contract, that the parties intended that it should extend over a year, recovery could not be had upon it, unless in writing.” But the rule so stated does not include an important element contained in the above quoted st

1933The modification of the rule stated in the case of In re Field’s Estate, supra, is tersely expressed in Tracy v. Barton, 139 Wash. 440 , 247 Pac. 734 , in the following language: “We have held that, when no time for the performance of a contract is fixed by the parties, if it nevertheless appears from the surrounding circumstances and, considering the object contemplated by the contract, that the parties intended that it should extend over a year, recovery could not be had upon it, unless in writing.” But the rule so stated does not include an important element contained in the above quoted st

1896Dec. 317 ); Woodman v. Dana, 52 Me. 9 ; State v. Hastings, 53 N. H. 452; Tyler v. Todd, 36 Conn. 218 ; Calkins v. State, 14 Ohio St. 222 ; Bragg v. Colwell 19 Ohio St. 407 ; Holmberg v. Johnson, 45 Kan. 19 ( 25 Pac. 575 ); Morrison v. Porter, 35 Minn. 425 ( 59 Am.

1896Dec. 317 ); Woodman v. Dana, 52 Me. 9 ; State v. Hastings, 53 N. H. 452; Tyler v. Todd, 36 Conn. 218 ; Calkins v. State, 14 Ohio St. 222 ; Bragg v. Colwell 19 Ohio St. 407 ; Holmberg v. Johnson, 45 Kan. 19 ( 25 Pac. 575 ); Morrison v. Porter, 35 Minn. 425 ( 59 Am.

1896Dec. 317 ); Woodman v. Dana, 52 Me. 9 ; State v. Hastings, 53 N. H. 452; Tyler v. Todd, 36 Conn. 218 ; Calkins v. State, 14 Ohio St. 222 ; Bragg v. Colwell 19 Ohio St. 407 ; Holmberg v. Johnson, 45 Kan. 19 ( 25 Pac. 575 ); Morrison v. Porter, 35 Minn. 425 ( 59 Am.

1896Dec. 317 ); Woodman v. Dana, 52 Me. 9 ; State v. Hastings, 53 N. H. 452; Tyler v. Todd, 36 Conn. 218 ; Calkins v. State, 14 Ohio St. 222 ; Bragg v. Colwell 19 Ohio St. 407 ; Holmberg v. Johnson, 45 Kan. 19 ( 25 Pac. 575 ); Morrison v. Porter, 35 Minn. 425 ( 59 Am.

1896Dec. 317 ); Woodman v. Dana, 52 Me. 9 ; State v. Hastings, 53 N. H. 452; Tyler v. Todd, 36 Conn. 218 ; Calkins v. State, 14 Ohio St. 222 ; Bragg v. Colwell 19 Ohio St. 407 ; Holmberg v. Johnson, 45 Kan. 19 ( 25 Pac. 575 ); Morrison v. Porter, 35 Minn. 425 ( 59 Am.