Motion to change custody & modify parenting time; Proper cause or a change of circumstances (COC); Deciding the motion without an evidentiary hearing

Finding no error requiring reversal, the court affirmed the trial court’s order denying defendant-father’s motion to change custody and modify parenting time. The case stemmed from his motion seeking a change of custody, modification of parenting time, and other relief. Defendant argued that he presented sufficient evidence of proper cause or a COC. “In light of the evidence that the child’s age-inappropriate behaviors were likely primarily caused by defendant’s behaviors, the trial court did not err by concluding that defendant failed to establish proper cause or a” COC sufficient to reconsider custody. Defendant also claimed the trial court abused its discretion by declining to hold an evidentiary hearing. The court concluded that the “trial court was able to reach an informed decision on the existing record, and its refusal to hold an evidentiary hearing was not ‘palpably and grossly violative of fact and logic . . . .’”