North Dakota Supreme Court Affirms 19 Make-Up Weekends for Father After Mother Withheld Children

The North Dakota Supreme Court upheld a contempt ruling against a mother who severed communication and blocked her children from seeing their father, affirming an order that grants him 19 consecutive make-up weekends.

Courtney Krueger had spent months locked out of his children's lives. His former partner, Christa Sandstrom, refused to let him exercise his court-ordered parenting time and abruptly cut off contact. Krueger fought back in district court, seeking immediate enforcement of the custody schedule. Sandstrom countered by demanding a formal modification of the custody decree, claiming conditions had altered significantly. The bench rejected her bid. Finding that Sandstrom had willfully and inexcusably defied the custody order, the trial judge held her in contempt, ordered 19 make-up weekends for Krueger, and slapped her with his legal fees. Sandstrom appealed. The state Supreme Court rejected every argument.

In its November 6, 2026, decision, the state's highest court ruled that the trial judge acted squarely within judicial discretion. The 19 weekends stood.

The Evidentiary Hearing and Criminal Inquiry Dispute

During the initial district court evidentiary hearing, Sandstrom sought to alter the existing custody baseline by introducing testimony from two witnesses concerning an active criminal investigation. The presiding judge refused to mandate testimony on that specific inquiry. Instead, the bench presented Sandstrom with a stark procedural choice: withdraw her motion to modify custody and refile it at a later date, or proceed immediately with the hearing stripped of those two witnesses.

She chose to push forward.

Having made that procedural gamble, Sandstrom later argued on appeal that the trial judge should have granted her a continuance and that the court had crippled her ability to prove a material change in circumstances. Under North Dakota legal standards, a parent seeking to alter an established parenting-time decree carries a strict evidentiary burden. That parent must prove not only that a material change in circumstances occurred since the prior order, but also that altering the schedule directly advances the best interests of the children. Such a change demands substantial new facts that were entirely unknown when the original decree took effect.

Yet the Supreme Court concluded that the trial court properly evaluated the abuse allegations and child-welfare factors before determining that no material change existed. The evidentiary rulings contained no clear error.

Remedial Relief vs. Punitive Sanctions

Sandstrom targeted the 19 make-up weekends directly on appeal, asserting the sanction was unconstitutionally punitive rather than corrective. She argued the trial court overstepped its statutory powers by imposing such an extensive compensatory schedule.

The high court dismantled that defense. In North Dakota, appellate review gives wide latitude to trial judges handling domestic relations and contempt enforcement. Remedial contempt sanctions are designed specifically to restore lost rights and coerce compliance, not to inflict retribution. Krueger lost months of court-sanctioned access to his children because of deliberate maternal interference. Handing those lost days back to him served as a direct remedy for the breach.

Besides challenging the custody schedule, Sandstrom contested the district court's jurisdiction to determine the father's legal fee award while an appeal remained pending. The Supreme Court cited North Dakota Rule of Civil Procedure 54(e)(2), which explicitly empowers trial courts to rule on timely fee applications even during parallel appellate filings.

Following the Supreme Court's affirmance, the case returns to the district court for formal enforcement of the make-up calendar and final execution of the attorney's fee award.