The Alaska Supreme Court has denied a mother's second attempt to obtain unsupervised visitation rights with her child, affirming a superior court order that requires continued supervision during visits. The memorandum opinion in *Nina T. v. Michael P.*, issued December 31, 2025, marks the second time Nina T. has unsuccessfully appealed the denial of her motion for unsupervised visitation.
The case stems from a 2021 child custody order issued by the Superior Court of Alaska, Third Judicial District in Anchorage, after Nina T. and Michael P. ended their relationship. Judge Laura Hartz presided over the original proceedings that established the current custody arrangement.
According to the court record, the 2021 custody order awarded Michael P. sole legal and primary physical custody of the child. The superior court limited Nina T. to supervised visitation after making several concerning findings about her conduct. The court determined that Nina T. had committed two acts of domestic violence, including felony custodial interference when she left Alaska with the child in violation of an interim custody order.
Additionally, the superior court found that Nina T. had knowingly presented "a falsified version of text messages" during the proceedings, though the complete details of this finding are not fully detailed in the available court record. These findings formed the basis for the court's decision to require supervised visitation rather than granting unsupervised access.
Nina T. represented herself pro se in both appeals, appearing from Sheridan, Oregon, while Michael P. was represented by attorney Darryl L. Thompson of Darryl L. Thompson, P.C., based in Anchorage. The case was heard by Chief Justice Carney and Justices Borghesan, Pate, and Oravec. Justice Henderson did not participate in the decision.
This latest appeal represents Nina T.'s continued efforts to modify the custody arrangement established in 2021. Her first appeal of the superior court's custody decisions was decided by the Alaska Supreme Court in July 2022, referenced as *Nina T. v. Michael P.*, No. S-18134, 2022 WL 2715660. The court noted in the current opinion that it would repeat only the facts relevant to this second appeal.
The Alaska Supreme Court's decision comes in the form of a memorandum opinion, which carries important limitations for future legal proceedings. As noted in the court's standard disclaimer, memorandum decisions do not create legal precedent. The court specifically advises that any party wishing to cite such a decision in a brief or during oral argument should review Alaska Appellate Rule 214(d) for proper procedures.
The memorandum opinion and judgment was entered under Alaska Appellate Rule 214, indicating it follows the state's established procedures for non-precedential decisions. The case was assigned Supreme Court number S-19320, with the original superior court case numbered 3AN-16-05910 CI.
The domestic violence findings that led to the supervised visitation requirement represent serious allegations that influenced the court's custody determination. Custodial interference, classified as a felony in this case, involves unlawfully taking or keeping a child in violation of a court order. Nina T.'s departure from Alaska with the child while an interim custody order was in effect constituted this offense according to the superior court's findings.
The requirement for supervised visitation serves as a protective measure designed to ensure the child's safety while maintaining some level of contact between the non-custodial parent and child. Such arrangements typically involve a neutral third party present during visits to monitor interactions and ensure compliance with court orders.
Family law cases involving domestic violence allegations often result in supervised visitation orders as courts prioritize child safety while attempting to preserve parent-child relationships where possible. The repeated appeals in this case demonstrate the ongoing tension between a parent's desire for expanded access and the court system's commitment to protective measures.
The fact that this represents Nina T.'s second unsuccessful appeal suggests that the evidence supporting the original custody determination was substantial enough to withstand multiple levels of review. Alaska's appellate courts generally defer to trial court findings of fact unless they are clearly erroneous, particularly in cases involving credibility determinations and domestic violence findings.
With this second appeal denied, Nina T.'s options for further challenging the supervised visitation requirement through the court system appear limited. Any future modifications to the custody arrangement would likely need to be pursued through the superior court with evidence of changed circumstances that would warrant altering the existing order.
The case highlights the challenges faced by non-custodial parents seeking to modify restrictive custody arrangements, particularly when the original orders were based on findings of domestic violence or custodial interference. Courts must balance parental rights with child protection, often erring on the side of caution when safety concerns have been established through judicial findings.