In Re the Marriage of Johansen

Debra Johansen appeals from a decision of the District Court for the Fifteenth Judicial District in Sheridan County, Montana, which modified custody by transferring primary residential custody from Debra to her former husband, Victor. Debra asserts that the District Court erred when it limited evidence at the custody modification hearing to post-dissolution decree evidence. We reverse the order of the District Court.

There are two issues on appeal.

1. Did the District Court commit reversible error when it limited evidence at the custody modification hearing to post-decree evidence?

2. Did the…