Section 12.27 Proof of Treatment and Rehabilitation

• Library: Family Law Deskbook and 2014 Supp

2. (§12.27) Proof of Treatment and Rehabilitation

If a court orders restricted or “supervised visitation because of allegations of abuse or domestic violence, a showing of proof of treatment and rehabilitation shall be made to the court before unsupervised visitation may be ordered.” Section 452.400.2(3), RSMo Supp. 2011. In In re Snoke v. Bordenaro, 913 S.W.2d 407 (Mo. App. W.D. 1996), the appellate court reversed the trial court’s order removing restrictions on the mother’s temporary custody rights that...