Shelstad v. Shelstad

[¶19.] On appeal, Sandra contends:

1. The circuit court lacked subject matter jurisdiction to determine custody.

2. The circuit court erred in concluding Duane did not have a history of domestic abuse.

3. The circuit court erred in determining Duane overcame the presumption under SDCL 25-4-45.5.

4. The circuit court abused its discretion in awarding primary physical custody to Duane.

Standard of Review

[¶20.] Questions of jurisdiction are reviewed de novo. Reaser v. Reaser , 2004 S.D. 116, ¶ 27, 688 N.W.2d 429, 437. We review child custody determinations for an abuse of discretion. Van Duysen v.…