In re the Marriage of Grippin

McAnany, J.:

Sonya Renee Pruett appeals the district court’s order granting primary residential custody of her son to her former husband, Michael William Grippin. Since the district court improperly imposed the búrden of proof on Pruett in entering its placement order, we reverse and remand for further proceedings consistent with this opinion.

Sonya’s and Michael’s son was bom in September 1996. Sonya and Michael married the following February. Their marriage was short-lived. Sonya filed for divorce 5 months later, in July 1997. The divorce was granted in October 1997, and Sonya was granted the…