This issue came before the court in Durbin v Durbin from Wake County. The parties had initially consented to a 50-50 shared parenting plan in 2020.  In reading between the lines, perhaps Mom was hoping the 50-50 consent order in 2020 would have ameliorated some of Dad's hard feelings towards her, but apparently not.

Mom alleged that Dad would continually fail to timely provide information to Mom and the parent coordinator, he was hostile and argumentative to the PC, he would refuse to cooperate with the PC and generally behaved like a jerk.  The trial court found a change of circumstances that had a negative impact on the children and reduced Dad's parenting time to every other weekend.

The question presented was whether ongoing conflict between the parents was sufficient to establish a change of circumstances permitting an action to modify custody, and whether such a change in circumstances adversely effected the children.

The Court of Appeals found that while a change in circumstances may be met by continued conflict between the parents, in this case there was no evidence in the record of adverse impact on the children.  The court found "...no specific findings linked the parties’ negative communication to the wellbeing of the children; and, in fact, the instances of conflict actually discussed by the trial court all appear to have been communications to which the children were not privy."

So, once again, facts matter!  If a parent wants to behave like a jerk, they can't involve the kids.  But... won't the kids pick up on the animosity between their parents anyway?  Perhaps, and if this is what is occurring, there must be a nexus between the parental behavior and the effect it has on the kids, and this finding must be in the record.