Krizan v. Krizan

VANDE WALLE, Chief Justice.

[¶ 1] Angela Erizan appealed from the trial court’s order denying her motion to amend the divorce judgment to change child custody, retroactively modify child support obligations and award costs and attorney’s fees. She also appealed from an earlier order sanctioning her attorney for unilaterally setting an alternate hearing date. We affirm in part, reverse in part and remand.

I

[¶ 2] Angela and John Erizan were married in 1979. Two daughters were born of the marriage, Jennifer and Joanna, born August 1, 1980 and June 20, 1982. In August 1991, Angela left the marital…