Cull v. Cull

Citations

• 2026 ND 10

Syllabus

The use of extended family members for childcare does not amount to a material change in circumstances unless it can be shown the arrangement has a detrimental effect on the children. A moving party must present competent evidence establishing a causal connection between alleged problems and the other parent's parenting. Merely alleging without support that problems stem from the other parent's parenting style is insufficient to establish a material change of circumstances. An isolated incident does not automatically mandate a finding of material change in circumstances, even when the incident involves potential endangerment to a child's physical or mental health.