supervised visitation

In 2003, a father murdered his seven-year-old daughter Andrea during a court-approved parental visitation. Ángela González, Andrea’s mother, had previously reported instances of physical abuse to the police on numerous occasions and sought court-ordered restraining orders against him to protect herself and her daughter. The father had refused to accept supervised visitations with his daughter. After killing his daughter, the father committed suicide. The mother brought suit in national court against Spanish authorities.

In Michelli v. Michelli, the plaintiff sought to overturn the trial court’s order granting the defendant supervised visitation of their children after a violation of their visitation agreement. The plaintiff had divorced the defendant after repeated physical abuse. The appellate court applied the Post-Separation Family Violence Relief Act, Louisiana Revised Statutes § 9:361 et seq. to the case, noting the delineated test had two elements: