The Court of Appeals in Wilkins v. Ferguson reversed the trial court’s order granting the biological father unsupervised visits and further expounded on modification of visitation orders when there is evidence of intrafamily offenses. After filing for absolute divorce, and seeking custody award from the court, the trial court granted joint legal custody with primary physical custody with the mother, Ms. Wilkins.  The trial court also found compelling evidence that husband had committed, and wife had suffered substantial physical, verbal and psychological abuse with the pattern of abuse existed throughout the marriage. The father-child visitation was later suspended due to
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