North Dakota Supreme Court
Edison v. Edison
October 24, 20242024 ND 196
Summary
The court affirmed the amended divorce judgment awarding Signe Edison primary residential responsibility and finding Jeffrey Edison underemployed for child-support purposes. It held that the district court’s comments and adverse rulings did not establish judicial bias, and that the court properly relied on Jeffrey’s tax return and statewide earnings evidence. Although the district court misapplied the self-employment-loss provisions and omitted refundable tax credits, those errors were harmless because Jeffrey remained underemployed under every legally permissible calculation.