Attorney reviewed by Sara Kim, a Washington-admitted attorney who handles the firm's family law matters. Last updated July 24, 2026.
A Washington parenting plan sets the residential schedule, and it can also restrict what a parent does during the time they have. Those two functions come from different statutes, and courts treat the second far more carefully than the first. A Division I decision filed July 20, 2026 affirmed an order confining a father's visits to King County unless the children themselves asked to travel, and barring both parents from raising the subject with them.
Restrictions on a parent's geographic location, travel, or conduct cannot be written in as ordinary parenting plan terms. They are available only under RCW 26.09.191, and only where the court makes a particularized finding of a specific level of harm. The Court of Appeals applied that framework in Dobbs v. Dobbs and concluded the trial court had made the findings it needed.
Where Parenting Plan Restrictions Come From
A parenting plan restriction is a court-ordered limit on a parent's residential time, decision making, or conduct, imposed because unrestricted contact would put the child at risk of harm. The residential schedule itself runs on a different track, through the best-interest factors, where the relative strength, nature, and stability of the child's relationship with each parent carries the greatest weight.
The distinction is not academic. The Washington Supreme Court held in In re Marriage of Chandola that limits on a parent's travel or conduct come only from RCW 26.09.191, not from the ordinary residential-schedule provisions. A trial court that dislikes an arrangement cannot simply write a condition into the plan and call it a scheduling term.
RCW 26.09.191 requires a court to limit residential time on any of these findings:
- Willful abandonment continuing for an extended period
- Physical abuse of a child, or a pattern of emotional abuse
- A history of acts of domestic violence as defined in RCW 7.105.010
- An assault causing grievous bodily harm or the fear of such harm, or any sexual assault
- Sexual abuse of a child
Separately, the statute lets a court limit a plan on a discretionary list that runs from neglect and substance abuse through the abusive use of conflict, closing with a catch-all for other conduct the court expressly finds adverse to the child's best interests. That catch-all is where most contested restrictions actually live, and it is the narrowest of the group.
The Statute Was Renumbered in 2025, and Older Opinions Still Use the Old Numbers
Anyone reading Washington parenting plan restrictions case law right now needs to know that the section was restructured in 2025. The discretionary list that used to sit at RCW 26.09.191(3) now sits at RCW 26.09.191(4)(c), and the catch-all that generations of briefs cited as subsection (3)(g) is now subsection (4)(c)(vii). The operative language did not change. The address did.
Opinions decided on dissolutions that predate the amendment apply the former version and say so. Dobbs is one of them, and the court wrote "former RCW 26.09.191" throughout. Reading the opinion against a current copy of the statute without noticing that will send you to a definition of "social worker" instead of the rule the court was applying.
Our family law attorneys at Blair Kim Moeller track this kind of renumbering across the King County Superior Court cases we handle, because a citation that was right in 2024 can point somewhere else entirely today.
What Division I Affirmed on July 20, 2026
The parents in Dobbs married in 2002, had two children, and bought a home on Mercer Island. The father traveled to Spain in late 2022 exploring a move, told his wife the following May that he wanted to separate, moved there that July, and filed for divorce in September 2023. Both children were teenagers when the case went to trial.
While a temporary parenting plan was in place, two conflicts arose around visits outside the scheduled times, including a Christmas Eve in which the father rented a place a block from the marital home rather than appearing by video as ordered. After trial, the court entered supplemental findings confining his visits to King County, permitting visits in Spain only at the children's request, and prohibiting either parent from encouraging or discouraging international travel.
The father argued on appeal that these were restrictions imposed without the findings the statute requires. The Court of Appeals disagreed and affirmed, along with the property division, the maintenance calculation, and the child support order. The decision is unpublished, so it is not binding precedent, but the framework it applies is settled law.
Parents on either side of a relocation dispute are usually working from an incomplete picture of what a court can actually order. Our attorneys can walk you through the findings a judge would need before any restriction attaches.
The Harm Finding Is the Whole Ballgame
The catch-all is deliberately hard to satisfy. Under Chandola, it reaches only harms similar in severity to the specific factors listed alongside it, which means a court cannot use it as a general grant of authority to fine-tune a parenting arrangement it finds untidy.
The harm also has to exceed what the Supreme Court in In re Marriage of Littlefield called the normal distress a child suffers because of travel, infrequent contact with a parent, or the other hardships that predictably follow a dissolution. A restriction that is not reasonably calculated to prevent a qualifying harm is an abuse of discretion.
For a parent facing proposed restrictions, that is the pressure point. The question is rarely whether the other parent's account of events is unflattering. It is whether the trial court identified a specific harm and tailored the limit to it, and whether the record supports the finding. The same analysis governs a child custody case in which restrictions are sought on the basis of domestic violence allegations, where the mandatory list rather than the catch-all applies.
Talk to a Seattle Family Law Attorney About Your Parenting Plan
Blair Kim Moeller, PLLC represents parents in parenting plan and relocation disputes in Seattle, Bellevue, and throughout King, Pierce, and Snohomish Counties. Sara Kim handles contested custody and parenting plan work and can tell you which findings a court would have to make before a restriction could attach to your time. Contact our office at 888-478-4001 or schedule a consultation to review your family law options.