You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Sweeney v. Kirby

Citation: 2013 ND 179Docket: 20130152

Court: North Dakota Supreme Court; October 22, 2013; North Dakota; State Supreme Court

Narrative Opinion Summary

Dawn M. Kirby appealed a trial court order from the Cass County District Court, presided over by Judge Steven L. Marquart, which denied her motion to modify the primary residential responsibility of her minor child. Kirby contended that she had presented adequate evidence to support her request for modification. However, the Supreme Court of North Dakota affirmed the trial court's decision, finding that the determination that Kirby failed to demonstrate a significant or material change in circumstances was not clearly erroneous. The court's ruling was issued per curiam, with no appearance by the plaintiff, Brian L. Sweeney, and the case was submitted on brief by Vanessa Rose Berge, representing the defendant and appellant.

Legal Issues Addressed

Modification of Primary Residential Responsibility

Application: The court evaluated the appellant's evidence but determined that there was no significant change in circumstances to warrant a modification of the custody arrangement.

Reasoning: Kirby contended that she had presented adequate evidence to support her request for modification. However, the Supreme Court of North Dakota affirmed the trial court's decision, finding that the determination that Kirby failed to demonstrate a significant or material change in circumstances was not clearly erroneous.

Standard of Review for Custody Decisions

Application: The Supreme Court applied the 'clearly erroneous' standard to review the trial court's findings regarding the change in circumstances necessary for custody modification.

Reasoning: The Supreme Court of North Dakota affirmed the trial court's decision, finding that the determination that Kirby failed to demonstrate a significant or material change in circumstances was not clearly erroneous.

Submission on Brief Without Oral Argument

Application: The case was decided based on written briefs without oral arguments, as indicated by the absence of the plaintiff and representation solely by the defendant's counsel.

Reasoning: The court's ruling was issued per curiam, with no appearance by the plaintiff, Brian L. Sweeney, and the case was submitted on brief by Vanessa Rose Berge, representing the defendant and appellant.