Lange v. Lange
In Lange v. Lange, 175 Wis. 2d 373, 502 N.W.2d 143 (Ct. App. 1993), the Court upheld a trial court order that the parent have reasonable supervised visitation, with the provision that the requirement of supervision could be removed when the parent showed he could visit without imposing his religious views on his children.
The Court concluded the restriction was valid under state law because Wis. Stat. 767.24(1) authorized the court to make "such provisions as it deems just and reasonable concerning the legal custody and physical placement" of a child; reasonableness was primarily a question of necessity and the record supported the court's implicit finding that it was necessary to protect the custodial parent's choice of religion for her children; the restriction was limited in scope; and the visiting parent had the power to terminate the restriction by showing he could visit without imposing his religious views. See Lange, 175 Wis. 2d at 382.