Wheedon & Gomer 2014 FamCAFC 141

A judge ordered that a child live with the mother and that unsupervised visits with the father commence only when the father was able to provide evidence of meeting three conditions: the father had undertaken continuous treatment for alcohol abuse with a psychiatrist or treating psychologist for six months (therapy for parent), with the therapist providing a report that the child would be safe spending unsupervised time with the father; and the father providing successive clean urine tests on a monthly basis for six months at times specified by the mother (access conditional, test for substances).

The father appealed the order.  The appeal was dismissed.