North Dakota Supreme Court

Diane Hendrickson, Plaintiff and Appellant v. Mark Hendrickson, Defendant and Appellee

January 25, 2000603 N.W.2d 896

Summary

The court affirmed the denial of Diane’s venue motion and upheld the change of custody to Mark because the record showed persistent visitation interference, parental alienation, exhaustion of other remedies, and a significant change of circumstances supporting the children’s best interests. It held that no additional evidentiary hearing was required because the prior proceedings supplied an adequate record and the remand authorized reconsideration of custody. The court reversed the one-year denial of all visitation and the provision allowing Mark to select Diane’s counselor, remanding for supervised visitation and court selection of a counselor from lists submitted by both parties.