Olsen also relies on J.M.G. v. J.C.G., where this court overturned the district court's sua sponte decision to transfer custody. 431 N.W.2d 592, 594 (Minn. App. 1988). In J.M.G., neither party argued that the district court lacked authority to transfer custody sua sponte, but only contended that the district court abused its discretion in the final custody decision.
The "failure to make findings of endangerment to support visitation restrictions is not necessarily grounds for reversal if the evidence in the record as a whole shows a parent's conduct endangers the child." J.M.G. v. J.C.G., 431 N.W.2d 592, 595 (Minn. App. 1988); see also Olson v. Olson, 534 N.W.2d 547, 550 (Minn. 1995).
Appellate courts review the district court's decision for an abuse of discretion, and the district court is required to have an "adequate factual basis before it subjects family members to the potentially traumatic effects of . . . therapeutic counseling." J.M.G. v. J.C.G., 431 N.W.2d 592, 595 (Minn. App. 1988). Here, the district court stated in its order that
Respondent argues that the district court's restriction was not based on Minn. Stat. ยง 518.18, but instead, was based on the court's findings that appellant is in need of treatment for boundary issues, relapse prevention, problematic sexual behavior, and mischaracterization of his initial relationship with Lundblad. It is unclear if this was the court's intention, however, here, such intention by the court would amount to an abuse of discretion. See J.M.G. v. J.C.G., 431 N.W.2d 592, 596 (Minn.App. 1988) (ordering father to participate in counseling as a condition of exercising his visitation rights, based on inconclusive evidence of sexual abuse, was abuse of discretion). A final word is appropriate on the issue of enforcement of this decision.
But failure to make this finding "is not necessarily grounds for reversal if the evidence in the record as a whole shows a parent's conduct endangers the child." J.M.G. v. J.C.G., 431 N.W.2d 592, 595 (Minn.App. 1988). And a district court, after ordering a change in custody, does not abuse its discretion by ordering that parenting time be supervised when evidence supports a finding that the child was endangered while in a parent's custody under the existing order.
Sept. 19, 1985), a case involving allegations of sexual abuse of a daughter by a father, the district court properly exercised its discretion in requiring the father's completion of a psychological rehabilitation program before further requests for visitation would be considered. Conversely, in J.M.G. v. J.C.G., 431 N.W.2d 592 (Minn.App. 1988), the district court's sua sponte transfer of custody and requirement of supervised visitation was an abuse of discretion because of the absence of evidence of abuse and endangerment of a child. Finally, in M.N.D. v. B.M.D., 356 N.W.2d 813 (Minn.App. 1984) there was no abuse of discretion in the district court's limitation of visitation to four hours of supervised visits per month, where the evidence was sufficient to show that the child was endangered by the father.