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In North Dakota, a mother’s decision to withhold her children from their father and stop communicating with him led to a contempt finding and an order granting the father 19 weekends of make-up parenting time. Parenting schedules are meant to ensure that children maintain relationships with both parents, but disputes can arise when one parent repeatedly prevents the other from exercising court-ordered parenting time.
How the parenting dispute developed
In a November 6, 2026, decision available on Justia, the North Dakota Supreme Court upheld the contempt ruling against Christa Sandstrom in a dispute involving Courtney Krueger. It also upheld the remedial sanction of additional parenting time, rejecting her argument that the 19 weekends were punitive rather than intended to address the missed visits. The district court subsequently denied her request to modify parenting time, found her in contempt and awarded Krueger 19 weekends of make-up parenting time as a remedial sanction.
The court found no clear error in the lower court’s conclusion that Sandstrom had willfully and inexcusably withheld the children from their father. The dispute eventually led to an evidentiary hearing in the district court. Sandstrom also sought to modify the existing parenting-time arrangement, arguing that circumstances had changed and that the court should reconsider the children’s schedule. During the hearing, she wanted two witnesses to testify about an ongoing criminal investigation. The court declined to require their testimony on that subject but gave her two options: withdraw her motion and refile it later, or continue with the hearing without those witnesses. Sandstrom chose to proceed. It also awarded him attorney’s fees.
The excluded testimony was relevant to her request to modify the existing parenting arrangement, according to her argument. Sandstrom appealed several parts of the district court’s decision. She argued that the court should have granted her a continuance after restricting the proposed testimony about the active criminal investigation. She also maintained that the district court’s findings were insufficient and that it had improperly limited her ability to present evidence of a material change in circumstances. Under North Dakota law, a parent seeking to modify parenting time must demonstrate that a material change in circumstances has occurred since the previous order and that the proposed modification would serve the children’s best interests. The state Supreme Court noted that a material change generally involves important new facts that were unknown when the original parenting-time order was entered. The district court had considered the abuse allegations and the factors relevant to the children’s best interests. It found that no material change in circumstances had been established. The Supreme Court concluded that these findings were sufficient and were not clearly erroneous.