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Richardson v. Richardson

Citation: 2022 ND 185Docket: 20220163

Court: North Dakota Supreme Court; November 9, 2022; North Dakota; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, an appellant sought to modify residential responsibility for his child, a legal process contingent upon demonstrating a material change in circumstances that adversely impacts the child. The district court denied the motion, as the appellant failed to establish the necessary prima facie case. The appellant also contested the denial of his reconsideration motion. However, North Dakota jurisprudence does not formally recognize motions for reconsideration, treating them instead as motions under Rule 59(j) or Rule 60(b) of the North Dakota Rules of Civil Procedure. The appellant did not comply with these procedural requirements, failing to cite relevant legal standards or provide substantial justification for his request. The Supreme Court, led by Chief Justice Jon J. Jensen, determined there was no abuse of discretion by the district court and affirmed the lower court's decision, maintaining the initial rulings and denying the appellant's motions for modification and reconsideration.

Legal Issues Addressed

Abuse of Discretion Standard

Application: A court's denial of a motion for reconsideration is reversible only if the court abuses its discretion.

Reasoning: The court clarified that denial of a reconsideration motion is only reversible if the district court abuses its discretion.

Modification of Residential Responsibility

Application: The appellant must demonstrate a material change in circumstances that adversely affects the child to modify residential responsibility.

Reasoning: The standard for modifying primary residential responsibility requires showing a material change in circumstances and that this change has negatively impacted the child.

Motions for Reconsideration in North Dakota

Application: North Dakota courts do not recognize motions for reconsideration and treat them as motions to alter or amend a judgment under Rule 59(j) or for relief from judgment under Rule 60(b).

Reasoning: North Dakota does not formally recognize motions to reconsider; instead, such requests are treated as motions to alter or amend a judgment under Rule 59(j) or for relief from judgment under Rule 60(b) of the North Dakota Rules of Civil Procedure.

Procedural Compliance in Appeals

Application: The appellant is required to cite relevant rules and substantiate claims for relief; failure to do so results in denial.

Reasoning: Richardson did not cite the relevant rules or provide arguments justifying relief as required.