FAMILY LAW
Supreme Court of Alaska (2023)
Kubi Johnson
In Christy v. Conrad, 524 P.3d 231 (Alaska 2023), the supreme court held parents can cut off contact between their children and the children’s grandparents, despite a positive grandparent-child relationship, if the grandparents are unable to show with clear and convincing evidence that ending visitation is detrimental to the children. Rebecca and Sam Christy, the paternal grandparents of two children, became the children’s legal parents after adopting them in June 2017. (Id. at 233). Following the adoption, the Christys cut off contact between the children and Marcie and Charles Conrad, the maternal grandparents. (Id.). The Conrads won visitation rights after filing a complaint in the superior court. (Id.). On appeal, the supreme court reasoned that the Conrads did not show with clear and convincing evidence that denying visitation is detrimental to the children. (Id. at 238). Although the children enjoyed seeing the Conrads, the record also showed the children had positive school experiences and generally thrived after the Conrads stopped visiting. (Id. at 237). Denying visitation did not harm the two children. (Id.). Accordingly, the supreme court reversed the superior court’s decision and held that parents can cut off their children from their grandparents despite a positive grandparent-child relationship, if the grandparents are unable to show with clear and convincing evidence that ending visitation is detrimental to the children. (Id. at 238).
