Taylor v. Taylor

Citations

• 970 N.W.2d 209
• 2022 ND 39

Syllabus

An attempted appeal from an order for judgment will be treated as an appeal from a subsequently entered consistent judgment, if one exists. A district court is generally not required to do a line-by-line best-interest analysis for each individual child, but factual findings should be stated with sufficient specificity for reviewing court to understand basis for its decision. Expert testimony is unnecessary for a showing that physical or emotional harm is likely to result from parenting time, and general testimony of a parent may suffice. Visitation with a noncustodial parent may be temporarily suspended where it is likely to endanger the children's physical or emotional health. District court order granting sole decisionmaking authority to custodial parent must be in the children's best interests. Visitation provisions controlled by custodial parent should be utilized only in exceptional circumstances and when custodial parent demonstrates willingness to foster parent-child relationship. Custodial parent may be permitted to monitor visitation between children and noncustodial parent.