Szczerkowski v. Karmelowicz
In Szczerkowski v. Karmelowicz, 60 Conn. App. 429, 432-33, 759 A.2d 1050 (2000), the defendant claimed that the court abused its discretion by modifying a visitation order without finding that there was a substantial change in circumstances. Id., 432.
The Court concluded that when considering motions to modify visitation, court's should apply the best interest of the child standard. Id.; see also General Statutes 46b-56.
General Statutes 46b-56 (b) provides in relevant part: "In making or modifying any order with respect to custody or visitation, the court shall (1) be guided by the best interests of the child, giving consideration to the wishes of the child if the child is of sufficient age and capable of forming an intelligent preference, provided in making the initial order the court may take into consideration the causes for dissolution of the marriage or legal separation if such causes are relevant in a determination of the best interests of the child . . . ."