Zittleman v. Bibler

Summary

The court affirmed the denial of Bibler’s motion to modify residential responsibility. It held that limiting the evidentiary hearing to five hours, allocating equal time to each party, and requiring Bibler to use her time for direct and cross-examination did not violate due process or constitute an abuse of discretion. Because Bibler failed to establish a material change in circumstances, the district court was not required to conduct a best-interests analysis or order remedies beyond the relief requested.