K.J.B. v. C.M.B.
Court of Appeals of Missouri for the Eastern District
779 S.W.2d 36 (Mo. Ct. App. 1989)
A divorced mother (plaintiff) and father (defendant) shared joint custody of their two children, and the mother petitioned to terminate the father's custody and visitation, alleging physical and psychological abuse; the parents agreed to suspend proceedings for counseling with psychiatrist Dr. Graham, who terminated the counseling after two sessions, finding the father uncommitted and further contact dangerous for the children. At the ensuing hearing, the mother's experts believed the children showed signs of abuse and favored primary custody to the mother (without recommending an end to supervised visitation), while the father's own expert acknowledged something abnormal in the father-child relationship but recommended maintaining it; the father requested further physical examination of the children, which the trial court denied as unnecessary and potentially harmful, before awarding the mother sole custody and terminating the father's visitation entirely, prompting his appeal.
Whether a court may order a parent to submit a child to physical or mental examinations for purposes of determining the best interests of the child in a custody proceeding.