North Dakota Supreme Court

Carvalho v. Carvalho

August 25, 20252025 ND 129

Summary

The North Dakota Supreme Court affirmed the district court’s denial of Cesar Carvalho’s motion to modify primary residential responsibility, holding that he failed to establish a prima facie case because his affidavits lacked competent evidence. The Court reiterated the de novo standard of review and the statutory requirement that a moving party show a material change of circumstances.