North Dakota Supreme Court

Sutherby v. Astanina

October 22, 20252025 ND 166

Summary

The North Dakota Supreme Court reversed the district court and remanded, holding that a district court must credit a noncustodial parent’s voluntary prejudgment child support payments when calculating past‑due support and that the district court erred in refusing such credit and in its discretionary choice of the support commencement date.