The dispute culminated in a district court evidentiary hearing where Sandstrom sought to modify the arrangement while Krueger petitioned to enforce his visitation. During the hearing, the judge declined to force two witnesses to address an active criminal investigation, but Sandstrom chose to proceed without them rather than refiling later. The North Dakota Supreme Court upheld the resulting contempt order, finding no abuse of discretion in the evidentiary limits or the remedy. Consequently, Krueger retains his award of attorney's fees alongside the 19 make-up weekends.
Key points
The state supreme court confirmed that providing 19 make-up weekends serves as an appropr…: The state supreme court confirmed that providing 19 make-up weekends serves as an appropriate remedial sanction rather than a punitive penalty.
Sandstrom failed to demonstrate the necessary material change in circumstances required t…: Sandstrom failed to demonstrate the necessary material change in circumstances required to modify the existing custody arrangement.
Appellate judges determined the lower court committed no clear error or abuse of discreti…: Appellate judges determined the lower court committed no clear error or abuse of discretion in its procedural and evidentiary rulings.
Sources checked by our analysis pipeline: 1
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. 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.
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. The court found no clear error in the lower court's conclusion that Sandstrom had willfully and inexcusably withheld the children from their father. 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.
How the parenting dispute developed
The case, Krueger v. Sandstrom, involved disagreements over parenting arrangements and allegations that Sandstrom had prevented Krueger from spending time with their children. Krueger sought enforcement of the existing parenting arrangement after the mother…
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