What is the current state of the law on overnight access for very, very young children?

Overnight access for very, young children is not uncommon in court-ordered parenting plans as indicated in the following cases. In Heuss v. Surkos, 2004 CarswellOnt 3517, the court permitted overnight access for a 28 month old child after reviewing case law which confirmed overnight access for young children. In addition, Spence J., delineated four relevant principles at para 30 as follows: I have referred to these cases in order to provide a sense of what direction the courts have taken in recent years in dealing with young, preschool children. What I glean from these cases are the following principles: First, it is important to maximize the contact between access parents and young children. Second, it is important that this contact be meaningful such that the relationship between them is allowed to flourish. Third, unless specific circumstances exist which point in a different direction, that contact should include regular overnight visits. And fourth, the overnights should be of sufficient duration and frequency to permit the relationship to flourish.