A court cannot modify parenting schedule-even if they find consent of the parties-without a showing of a substantial change in circumstances

In Brown v. Brown, 38 FLW D2247a (fla 1st DCA) opinion filed October 25, 2013, the DCA found error in the modification of a judgement of dissolution (magistrate's findings adopted by the trial court) without a showing of a substantial and material change in circumstances even though the court determined from the evidence that the parents consented to extra visitation.
Full opinion follows:
PER CURIAM. Telissa A. Brown, the former wife, appeals a final judgment which modifies a previously entered judgment of dissolution. Because there was no showing of a substantial and material change in circumstances, we reverse.