McBride-Kramer v. Kramer

KAUTZ, Justice.

[¶1] Following a bench trial, the district court awarded the appellee, Samuel B. Kramer (Father), primary physical custody, and the appellant, Sarah McBride-Kramer (Mother) visitation, of the couple's daughter (the child). Mother appeals the order, arguing the district court abused its discretion when it refused to allow her to call one of the child's counselors, who had not been previously designated as a witness, to testify at trial. We affirm.

ISSUE

[¶2] Mother identified two issues on appeal; however, they involve the same ruling. Therefore, we distill Mother's issues to one:

W…