You write that "a father’s failure to attend counseling mandated by court order is a sufficient change in circumstances to modify an earlier visitation order." Although your research did not find a case directly on point for this proposition, you did find a case "holding that a father’s failure to use alternative dispute resolution procedures mandated in a prior court order constituted a change in circumstances sufficient to modify a support order." This case is Peter Q. Harris versus Bonnie L. Harris. This is a 1998 opinion of the Supreme Court of Vermont reported in volume 714, page 626, of Atlantic Reporter, Second Series. Although the holding in Harris is different from the proposition in your brief, it is sufficiently analogous to lend support to your position. Draft the citation that should follow your statement.