COLIN JACOB HINDS v. SYDNEY PETITE HINDS (2026)

This matter involves a child custody/visitation dispute. Relator, Colin Hinds, seeks review of the trial court's January 20, 2026 judgment, which granted the motion for new trial of Respondent, Sydney Petite Hinds, and determined that La. R.S. 9:362(7), a provision of the Post-Separation Family Violence Relief Act (“Family Violence Act”), invalidated consent judgments which designated Relator's parents and/or brother as visitation supervisors. For the reasons that follow, we grant Relator's writ, vacate the trial court's judgment, and remand for further proceedings consistent with this opinion.

FACTUAL AND PROCEDURAL HISTORY

The present custody dispute herein relates back to consent judgments entered between the parties in 2018 and made executory in 2020. The 2018 Consent Judgment provided, in part, “that in consideration for Sydney Hinds dismissing with prejudice two (2) Petitions for Protection filed pursuant to La. R.S. 46:2136 and R.S. 9:362, the parties agree that sole custody is awarded to Sydney Hinds of the minor children, subject to supervised visitation by Colin Hinds ․” Relator's parents and brother were approved as visitation supervisors in the 2020 Consent Judgment.

On June 27, 2021, Respondent filed a Motion for Modification of Supervisors, seeking to remove Relator's father as a visitation supervisor on the grounds of the father's alleged sexual abuse. The trial court granted the motion. This Court affirmed; however, the Supreme Court vacated the judgment, finding that Respondent had not met her burden of proof.¹ Thereafter, Relator filed a motion for reinstatement of supervised visitation and request to find Respondent in contempt. The trial court granted Relator's reinstatement and contempt motions.

On September 9, 2024, Respondent filed a Motion for Termination of Designated Visitation Supervisors (“motion to terminate”), alleging Relator has a history of family violence. As such, Respondent averred the 2018 Consent Judgment, specifically confected pursuant to the Family Violence Act, was invalid because La. R.S. 9:362 of the Act presumptively restricts supervision by relatives of a parent with a history of family violence. In response, Relator filed an Expedited Motion for Contempt, to Terminate Child Support, and to Reset Motions for Contempt and to Modify Custody (“motion for contempt”). Relator asserted Respondent had willfully refused to comply with the trial court's order to reinstate supervised visitation. On March 19, 2025, the trial court denied Respondent's motion to terminate designated supervisors and granted Relator's motion for contempt.²

On March 25, 2025, Respondent filed a motion for new trial. Subsequently, on May 8, 2025, Relator filed a motion for ex parte custody, seeking temporary custody of the minor children. The trial court rendered judgment on January 20, 2026, granting Respondent's motion for new trial, which encompassed terminating Relator's brother and parents as visitation supervisors and vacating the judgment which found Respondent in contempt.³ Further, the trial court denied Relator's ex parte motion for custody.

Thereafter, Relator timely filed the present writ application seeking review of the judgment which granted Respondent's motion for new trial.⁴

ASSIGNMENTS OF ERROR

Relator's assignments of error collectively fall within two categories: 1) the trial court committed error by invalidating the consent judgments pursuant to the Family Violence Act, without a judicial finding of family violence; and 2) the trial court erred in granting Respondent's motion for new trial and the resulting relief granted in vacating the March 19, 2025 motion for contempt order against Respondent.

DISCUSSION

Family Violence Act; Validity of Consent Judgment

This Court discussed the purpose of the Family Violence Act in Durand v. Rose, as follows:

The Post-Separation Family Violence Relief Act (“Family Violence Act”) was designed to protect a child's interest by restricting the rights of an abusing parent in families with a history of family violence. Michelli v. Michelli, [19]93-2128, p. 5 (La. App. 1 Cir. 5/5/95), 655 So.2d 1342, 1346. The statute creates a presumption that “no parent who has a history of perpetrating family violence” shall be awarded sole or joint custody of children. La. R.S. 9:364(A). Moreover, “[i]f the court finds that a parent has a history of perpetrating family violence, the court shall allow only supervised child visitation with that parent pursuant to [La.] R.S. 9:341.”

2022-0300, p. 3 (La. App. 4 Cir. 9/15/22), 366 So.3d 484, 489 (second and third alterations in original). In conjunction with the purpose of the Family Violence Act, La. R.S. 9:362(7) states, in relevant part, that “[t]he supervising person shall not be any relative, friend, therapist, or associate of the parent perpetrating family violence.”

In this matter, the trial court's judgment specifically found the designation of Relator's parents and/or brother as visitation supervisors as outlined in any consent judgment was “contrary to law” as set forth in La. R.S. 9:362. However, we agree with Relator that established jurisprudence, as noted in Durand, supra, and exemplified in related jurisprudence cited herein below, supports there must first be a judicial finding of a history of perpetrating family violence in order to enforce the provisions of the Family Violence Act.

In Cockheran o/b/o Cockheran v. Christopher, 2021-0370, 0371, pp. 3-4 (La. App. 4 Cir. 10/28/21), 331 So.3d 389, 392, the mother “filed an “Amended Petition for Sole Custody and Permanent Injunction pursuant to La. R.S. 9:361 et seq. Post-Separation Family Violence Relief Act,” seeking sole physical and legal custody of the minor child and denial of visitation by the father. The Cockheran Court determined that the abuse allegations raised in the mother's petition were sufficient to trigger the application of the Family Violence Act. Id. at p. 7, 331 So.3d at 394. Thereafter, in affirming the judgment to grant an order of protection, this Court noted “the trial court found that the testimony of witnesses and photographs of the injuries were persuasive in determining the history of family violence.” Id. at pp. 11-12, 331 So.3d at 396.

Similarly, in Petite, 2024-00010, p. 1, 380 So.3d at 554 (Petite II), the Supreme Court considered whether there was sufficient evidence to find the petitioner had met her burden of proof to be entitled to a protective order. As referenced herein, this matter included the same parties involved in the present matter. In that instance, Respondent had filed a Petition from Protection from Abuse pursuant to La. R.S. 46:2131, et seq.,⁵ against Relator's father to remove him as a visitation supervisor. See Petite, 2023-0262, p. 1, 382 So.3d at 328 (Petite I). Contrary to Cockheran, supra, the Supreme Court found Respondent had not met her burden of proving the allegations of abuse in order to obtain an order of protection; and accordingly, vacated the order of protection issued by the trial court and affirmed on appeal. Petite II, 2024-0010, p. 1, 3820 So.3d at 554.

Cockheran, Petite I, and Petite II all underscore there must be a finding of family violence or abuse prior to enforcement of the provisions of the Family Violence Act. A protection order will only issue upon a showing of good cause by the petitioner. Carrie v. Jones, 2021-0659, p. 9 (La. App. 4 Cir. 1/21/22), 334 So.3d 834, 842 (citing McKinsey v. Castle, 2021-0368, p. 5 (La. App. 4 Cir. 8/10/21), 2021 WL 3522093, at *2). Moreover, the party seeking relief has the burden to prove the abuse allegations by a preponderance of the evidence. Id. (first citing La. R.S. 46:2135(A); and then citing Rodriguez v. Claasen, 2016-0610, 0611, pp. 9-10 (La. App. 4 Cir. 12/21/16), 207 So.3d 490, 496-97). This procedure did not occur in the present matter. Here, the trial court effectively invalidated the consent judgments and removed Relator's family as visitation supervisors based on Respondent's unproven allegations of family violence. Accordingly, Relator's claim that the trial court erred in finding the “consent judgments” contravened the Family Violence Act and the resulting removal of Relator's parents and/or brother as visitation supervisors—without a finding of family violence—is meritorious.

Motion for New Trial

The record reflects that the trial court's judgment granting Respondent's motion for new trial was predicated on the trial court's invalidation of the consent judgments. Therefore, having found that the trial court erred in invalidating the consent judgments without a finding of family violence, we likewise vacate the judgment granting Respondent's motion for new trial.

Remand

Notwithstanding that the trial court prematurely invalidated the consent judgments, we also find the consent judgments do not preclude Respondent or any party from bringing a claim to enforce the provisions of the Family Violence Act. Relator suggests that Respondent should be bound by the terms of the 2018 Consent Judgment wherein Respondent agreed to drop abuse allegations against Relator in consideration for Respondent's receipt of sole custody. However, we find enforcement of such an agreement would violate public policy enunciated in the Family Violence Act and other statutory provisions to protect children against family violence. Additionally, the provisions of the Family Violence Act “only requires evidence of past events of family violence and does not require that the events be frequent or continuous.” Durand, 2022-0300, p. 5, 366 So.3d at 490 (citation omitted). Thus, on remand, Respondent may re-urge abuse allegations that may have occurred during the time that the consent judgments were entered, provided the allegations have not been previously tried and resolved in a judicial proceeding.

DECREE

Based on the foregoing reasons, we grant Relator's writ application. The trial court's judgment is vacated and the matter is remanded for further proceedings consistent with this opinion.

WRIT GRANTED; JUDGMENT VACATED; AND REMANDED

I respectfully concur in part and dissent in part. I would grant the writ application of Relator Colin Hinds (“Father”) and exercise this Court's supervisory jurisdiction. Upon review, I would affirm the January 20, 2026 judgment in part, vacate Paragraph 2 of that judgment, and remand with limited instructions for a contradictory hearing on the prospective designation of appropriate visitation supervisors.

The district court erred in finding that the designation of Father's parents and/or brother as visitation supervisors in any consent judgment was contrary to law under La. R.S. 9:362(7). Moreover, I disagree with the majority's broader disposition remanding for proceedings that would permit Sydney Hinds (“Mother”) to re-urge allegations of family violence against Father and vacating the January 20, 2026 judgment in its entirety rather than limiting the vacatur to the specific error identified. Neither action is warranted, for the reasons set forth below.

In the January 20, 2026 judgment, the district court maintained supervised visitation, vacated the prior contempt ruling against Mother, vacated the order requiring Mother to pay attorney's fees and costs, vacated the seven-month suspension of Father's child-support obligation, vacated the order requiring Mother to comply with the September 5, 2024 judgment, denied Father's ex parte custody motion, and ordered that future supervisors meet the criteria of La. R.S. 9:362(7), which provides:

“Supervised visitation” means face-to-face contact between a parent and a child which occurs in the immediate presence of a supervising person approved by the court under conditions which prevent any physical abuse, threats, intimidation, abduction, or humiliation of either the abused parent or the child. The supervising person shall not be any relative, friend, therapist, or associate of the parent perpetrating family violence. With the consent of the abused parent, the supervising person may be a family member or friend of the abused parent. At the request of the abused parent, the court may order that the supervising person shall be a police officer or other competent professional. The parent who perpetrated family violence shall pay any and all costs incurred in the supervision of visitation. In no case shall supervised visitation be overnight or in the home of the violent parent.

Id

Paragraph 2 of the January 20, 2026 judgment provides, in pertinent part:

For the reasons set forth in Defendant's Supplemental Notice of Termination of Visitation Supervisors and Defendant's Motion for Termination of Designated Visitation Supervisors, the designation of Colin Hinds's parents and/or brother as his visitation supervisors in any ‘consent judgments’ is contrary to the law, and prospectively any such visitation supervisors must meet the criteria set forth in R.S. 9:362(7), such as Tanya Brancato; Janet Stoudemire; Leon Petite, Jr.; Leon Petite, III; John Decastra; Nick McClendon; and, any Birmingham or Mountain Brook, Alabama law enforcement officer[.]

Father seeks supervisory review, arguing that the district court committed legal error in its interpretation of the consent judgments and its application of La. R.S. 9:362(7). The interpretation of a consent judgment presents a question of law, as consent judgments are construed according to the same principles applicable to contracts. Jones v. City of New Orleans, 20-0247, p. 5 (La. App. 4 Cir. 4/14/21), 315 So.3d 963, 967 (citing La. C.C. art. 2045). The application of a statute likewise presents a question of law. Benjamin v. Zeichner, 12-1763, p. 5 (La. 4/5/13), 113 So.3d 197, 201. Therefore, I review both questions de novo.

Upon my de novo review, I would vacate Paragraph 2 because the district court erred in finding that the designation of Father's parents and/or brother as visitation supervisors in any consent judgment was contrary to law under La. R.S. 9:362(7). The 2018 ¹ consent judgment awarded Mother sole custody of the minor children, subject to Father's supervised visitation, in consideration of Mother's dismissal with prejudice of two petitions for protection. The January 16, 2020 consent judgment thereafter designated Father's mother, Father's father, and Father's brother as visitation supervisors “without prejudice to either party.” This language preserves either party's right to seek prospective modification or reconsideration of the supervisor designation. It does not render the 2020 supervisor designation void from inception under La. R.S. 9:362(7). Moreover, the combined effect of the 2018 compromise, the dismissal with prejudice of the protection petitions, the absence of judicial finding that Father was a “parent perpetrating family violence,” and the 2020 “without prejudice” designation preserving prospective modification or reconsideration, support this conclusion. I therefore would vacate Paragraph 2, including its treatment of the family-member supervisor designation in “any consent judgments” as invalid or void under La. R.S. 9:362(7).

This Court, in the exercise of its supervisory jurisdiction, may correct the legal error presented by Paragraph 2 without vacating the January 20, 2026 judgment in its entirety. This Court has vacated a judgment and remanded for a contradictory hearing when the district court proceeded under an incorrect legal framework and further proceedings were necessary to implement the correct one. See Walker v. Brown, 24-0198, pp. 4-7 (La. App. 4 Cir. 5/17/24), 390 So.3d 427, 430-32 (citing appellate court's constitutional and codal authority to correct procedural and legal errors sua sponte and to vacate trial court's judgment and remand for a contradictory hearing); see also La. C.C.P. art. 2164 (providing that the appellate court “shall render any judgment which is just, legal, and proper upon the record on appeal”). Because the prospective designation of appropriate visitation supervisors requires factual determinations that are best made by the district court in the first instance, remand for a contradictory hearing limited to the prospective suitability of parent of Father (“Grandfather”) and any other proposed supervisors is the appropriate remedy. Harris v. Doucette, 539 So.2d 997, 999 (La. App. 4th Cir. 1989) (recognizing the trial court “is in a better position than the appellate court to evaluate the credibility of witnesses and the weight of the evidence”) (citation omitted).

I find the majority errs by remanding with instructions that would permit Mother to re-urge allegations of family violence against Father and by vacating the January 20, 2026 judgment in its entirety rather than limiting the vacatur to the specific error identified. Neither action is warranted.

As to whether Father is a perpetrator of family violence, that inquiry is unnecessary to resolve this writ and would require the parties and the children to relitigate the historical circumstances that produced the consent judgment years ago. Such a remand risks precisely the harm the Legislature sought to prevent when it recognized that, in cases involving family violence, “child custody and visitation become the new forum for the continuation of the abuse,” and that ordinary custody rules may work against protection because of “the unique dynamics of family violence.” La. R.S. 9:361.

The parties’ prior 2018 consent judgment already provides the operative framework. Mother received sole custody. Father received supervised visitation. Father agreed that his supervised visitation would be conducted pursuant to La. R.S. 9:361, et seq. Father also agreed to comply with La. R.S. 9:364(B) before seeking to modify custody or visitation. The judgment further states that Father's agreement was not an admission that he has a history of perpetrating family violence. Thus, the consent judgment avoided a formal adjudication while still requiring Father to comply with agreed statutory conditions before seeking modification.

The non-admission clause may prevent the 2018 consent judgment from being treated as a formal adjudication that Father is a parent who has perpetrated family violence for every statutory purpose. But the non-admission clause does not dissolve Father's prospective obligations under the same consent judgment. Father accepted supervised visitation and the requirement that he comply with La. R.S. 9:364(B) before seeking to modify custody or visitation. Father should not be permitted to rely on the non-admission clause while avoiding the conditions he accepted as part of the same compromise. These two aspects of the 2018 consent judgment must be read together.

La. R.S. 9:364(B) provides:

The presumption shall be overcome only if the court finds all of the following by a preponderance of the evidence:

(1) The perpetrating parent has successfully completed a court-monitored domestic abuse intervention program as defined in R.S. 9:362, or a treatment program designed for sexual abusers, after the last instance of abuse.

(2) The perpetrating parent is not abusing alcohol or using illegal substances scheduled in R.S. 40:964.

(3) The best interest of the child or children, considering the factors listed in Civil Code Article 134, requires the perpetrating parent's participation as a custodial parent because of the other parent's absence, mental illness, substance abuse, or other circumstance negatively affecting the child or children.

Id.

The 2018 consent judgment required Father to comply with that statutory framework before seeking modification of custody or visitation. Father therefore remains subject to supervised visitation unless and until he satisfies the conditions imposed by the consent judgment and carries the applicable burden for modification. A retrospective hearing to determine whether Father should now be adjudicated a perpetrator of family violence is unnecessary to maintain supervision already imposed by consent judgment. The relevant inquiry is whether Father has complied with the judgment's conditions and whether any proposed modification of custody or visitation is authorized under the governing custody and visitation standards, not whether Father should be formally adjudicated a perpetrator at this late stage.

The majority's approach creates the risk of additional harm. This case has already involved years of litigation, multiple consent judgments, protective-order proceedings, contempt proceedings, writs, and repeated disputes over visitation. Sending the matter back for a broad inquiry into whether Father is a perpetrator of family violence reopens the very controversy the parties compromised when Mother received sole custody and Father received supervised visitation. That remand does not advance stability for the children. It risks further delay, renewed allegations, renewed defenses, and renewed uncertainty over a custody structure that already limits Father to supervised visitation.

The Family Violence Act was enacted because domestic violence custody cases require flexibility and attention to context, not rigid formalism. La. R.S. 9:362 requires court-monitored domestic abuse intervention programs to include training in the “causes and dynamics of domestic violence, characteristics of batterers, victim safety, and sensitivity of victims.” La. R.S. 9:362(3)(c). In State v. Koederitz, 14-1526 (La. 3/17/15), 166 So.3d 981, the Louisiana Supreme Court similarly recognized, in the evidentiary context, that domestic violence cases require attention to relationship context, treatment, safety, and prevention of future injury. Although Koederitz arose in a criminal evidentiary posture, its reasoning supports the broader principle that courts should not analyze domestic violence matters through rigid formalism detached from context.

That principle applies with particular force in custody and visitation matters. The court's focus should be on the children's present safety and stability, not on relitigating old allegations when the existing judgment already requires supervised visitation and imposes conditions on Father before modification. La. C.C. art. 134 provides that “[t]he potential for the child to be abused” is “the primary consideration” in determining best interest. La. C.C. art. 136 further provides that a parent not granted custody is entitled to reasonable visitation only “[s]ubject to R.S. 9:341 ² and 364 ³ .” This approach counsels against a remedy that sends the parties backward to relitigate historical allegations when the existing consent judgment already imposes supervised visitation and conditions on Father before modification. The proper focus at this stage is prospective and whether the proposed supervisors are appropriate and whether the visitation structure protects the children's safety and best interest.

Louisiana custody modification principles also support this approach and result. Tracie F. v. Francisco D., 15-1812, p. 2 (La. 3/15/16), 188 So.3d 231, 235, recognizes that when the prior decree is a stipulated or consent judgment, the mover must prove a material change in circumstances and that the proposed modification is in the child's best interest. In the case sub judice, Father is the party seeking to move beyond the existing supervised visitation structure and the conditions of the judgment he accepted. He therefore bears the burden of pursuing modification.

The only issue requiring remand is the prospective supervisor issue. Grandfather was one of the supervisors designated in the January 2020 consent judgment. A subsequent protective order proceeding involving Grandfather was vacated by the Louisiana Supreme Court, finding Mother did not satisfy her burden of proof. Petite v. Hinds, 24-00010 (La. 3/12/24), 380 So.3d 553. That ruling only addressed the validity of the protective order. And while it cannot be treated as a proven adjudication of abuse by Grandfather, it does not limit the district court's vast discretion over supervisory arrangements on remand. See Coie v. Coie, 42,077, pp. 7-8 (La. App. 2 Cir. 2/21/07), 948 So.2d 1276, 1279-80 (holding that expiration of a domestic-abuse protective order on its own terms did not preclude the trial court from enforcing supervised visitation).

La. R.S. 9:362(7) defines supervised visitation as face-to-face contact between parent and child in the immediate presence of a court-approved supervisor “under conditions which prevent any physical abuse, threats, intimidation, abduction, or humiliation of either the abused parent or the child.” That language gives the district court continuing authority to decide whether Grandfather, or any other proposed supervisor, is presently appropriate. The determination should be made after a contradictory hearing focused on the suitability of Grandfather and any proposed supervisors, not on relitigating whether Father is a perpetrator of family violence.

Furthermore, I disagree with the majority's decision to vacate the January 20, 2026 judgment in its entirety rather than limiting the vacatur to the specific error identified. The majority's approach has the effect of reinstating the contempt ruling, the attorney's fee award, the child support suspension, and the order compelling compliance with the September 5, 2024 judgment, all of which the district court vacated as part of the same judgment. Those rulings should not be reinstated automatically merely because Paragraph 2 was legally erroneous. Because the district court acted within its discretion in vacating them, this Court's ruling on supervisory review should reach no further than the specific error committed.

I would affirm the district court's decision to grant a new trial and vacate the contempt ruling. A trial court's decision to grant a motion for new trial is reviewed for an abuse of discretion. Lepree v. Dorsey, 22-0853, p. 22 (La. App. 4 Cir. 8/11/23), 370 So.3d 1191, 1204-05 (citations omitted). Similarly, a finding of contempt and the imposition of sanctions are reviewed under an abuse of discretion standard. Succession of Bailey, 20-0145, p. 4 (La. App. 4 Cir. 11/18/20), 311 So.3d 422, 425 (citations omitted). The district court did not abuse its discretion in either respect.

The contempt ruling was tied to Mother's refusal to allow visitation with the challenged family member supervisors. Once the district court determined that the supervisor arrangement required reconsideration, it was within the court's discretion to vacate the contempt adjudication, attorney fee award, and child support suspension, and order compelling compliance with the September 5, 2024 judgment. The majority's decision to vacate the January 20, 2026 judgment in its entirety necessarily reinstates those sanctions. This result is neither compelled by the writ record nor consistent with the limited error the majority itself identifies. I would not reinstate those contempt sanctions on writ review.

This is especially true as to the suspension of child support. La. R.S. 9:346 authorizes remedies for failure to exercise or allow court-ordered visitation, including contempt, actual expenses, additional visitation, attorney fees, costs, and counseling costs. It also recognizes a defense where the failure to allow or exercise visitation was by mutual consent, beyond the party's control, or for other good cause shown. La. R.S. 9:346 does not support reinstating a child support suspension on this writ record without careful analysis of the statutory basis and the children's interests.

For these reasons, I would grant Father's writ application and exercise this Court's supervisory jurisdiction. On the merits, I would affirm the January 20, 2026 judgment in part, vacate Paragraph 2 of that judgment, and remand with instructions that the district court conduct a contradictory hearing limited to the prospective designation of appropriate visitation supervisors, including whether Grandfather may serve as a supervisor. I would affirm the January 20, 2026 judgment in all other respects.

FOOTNOTES

1.   Petite v. Hinds, 2023-0262 (La. App. 4 Cir. 10/31/23), 382 So.3d 325, rev'd in part on reh'g (Dec. 4, 2023), writ granted, decision vacated, 2024-00010, p. 1 (La. 3/12/24), 380 So.3d 553-54.

2.   The written judgment was not signed until May 7, 2025.

3.   The January 20, 2026 judgment stated, in part, the following:IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that:1) Defendant's motion for new trial relative to the judgment signed on May 7, 2025, following the hearing and oral ruling on March 19, 2025, is GRANTED, in the following respects: A) the adjudication finding Defendant Sydney Petite in contempt of court is VACATED; B) the order requiring Defendant Sydney Petite to pay attorney's fees and costs is VACATED; C) the order suspending Plaintiff's Colin Hinds’[ ] child support payments for seven (7) months is VACATED; D) the order requiring Defendant Sydney Petite to comply with the September 5, 2024[ ] judgment is VACATED; and2) For the reasons set forth in Defendant's Supplemental Notice of Termination of Visitation Supervisors and Defendant's Motion for Termination of Designated Visitation Supervisors, the designation of Colin Hinds’[ ] parents and/or brother as his visitation supervisors in any “consent judgments” is contrary to law, and prospectively any such visitation supervisors must meet the criteria set forth in R.S. 9:362 ․

4.   All parties were granted an opportunity to respond and reply to the writ application.

5.   See Cockheran, 2021-0370, 0371, p. 6, 331 So.3d at 393, which notes that “while the apparent legislative intent in creating the [Family Violence] Act was to protect victimized parties when domestic disputes arise in the course of separation and divorce, the Act has the same effect of La. R.S. 46:2131 et seq., the Protection from Family Violence Act. The intent of the statutory provisions is to protect children in abusive situations.”

1.   The parties signed this judgment in 2018; however, the district court did not sign the judgment until February 2019. This dissent refers to it as the “2018 consent judgment” for consistency with the majority.

2.   La. R.S. 9:341 governs the conditions and requirements for supervised visitation in cases involving family violence.

3.   La. R.S. 9:364 sets forth the presumption against awarding custody to a parent with a history of perpetrating family violence and the conditions a perpetrating parent must satisfy to overcome that presumption. The pertinent provisions of La. R.S. 9:364(B) are discussed in the body of this opinion.

Judge Sandra Cabrina Jenkins

LOBRANO, J., CONCURS IN PART AND DISSENTS IN PART WITH REASONS