North Dakota Supreme Court upholds 19 make-up weekends after mother withholds children from father

Parenting schedules are meant to ensure that children maintain relationships with both parents, but disputes can arise when one parent repeatedly prevents the other from exercising court-ordered parenting time. In North Dakota, a mother's decision to withhold her children from their father and stop communicating with him led to a contempt finding and an order granting the father 19 weekends of make-up parenting time.In a November 6, 2026, decision available on Justia, the North Dakota Supreme Court upheld the contempt ruling against Christa Sandstrom in a dispute involving Courtney Krueger. The court found no clear error in the lower court's conclusion that Sandstrom had willfully and inexcusably withheld the children from their father. It also upheld the remedial sanction of additional parenting time, rejecting her argument that the 19 weekends were punitive rather than intended to address the missed visits.How the parenting dispute developedThe case, Krueger v. Sandstrom, involved disagreements over parenting arrangements and allegations that Sandstrom had prevented Krueger from spending time with their children. Krueger sought enforcement of the existing parenting arrangement after the mother allegedly withheld the children and stopped communicating with him. The dispute eventually led to an evidentiary hearing in the district court.