M.M. Missouri Cases

In a paternity suit, Father appealed the trial court's judgment awarding him supervised visitation with one of the parties' minor children, O.S., for four hours every other Saturday. Father argued the judgment was unsupported by substantial evidence and that the trial court improperly relied on unsworn statements from the guardian ad litem (GAL). The appellate court reversed the portion of the judgment related to O.S.'s visitation schedule, finding the trial court erred by relying on the GAL's unsworn statements and that, absent those statements, the order was not supported by substantial evidence. The case was remanded for further proceedings on the visitation issue, with the judgment affirmed in all other respects.