Slappy v. Slappy

Citations

• 965 N.W.2d 408
• 2021 ND 186

Syllabus

To modify primary residential responsibility after two years, the moving party must meet the requirements of the statutory framework, including that there has been a material change in circumstances of the child or the parties, and that modification is necessary for the best interests of the child. \Necessary\ for the best interests of the child means there must be a showing that the changed circumstances had an adverse effect on the child or there had been a general decline in the child's condition. Because continuity and stability in a child's life is favored, an improvement to the moving party's life, without evidence of an adverse effect or general decline in the child, is insufficient to modify primary residential responsibility.