Huesers v. Huesers

*881MESCHKE, Justice.

[¶ 1] Stuart Huesers appealed an amended decree placing custody of his children -with their mother, Marla Huesers. We hold the trial court should have considered the 1997 legislative amendments to NDCC 14-09-06.2(l)(j) but, under the amendments, Stuart’s conduct, as a matter of law, constituted a pattern of domestic violence within a reasonable time proximate to the litigation. Thus, the court’s error was harmless, and we affirm.

[¶ 2] Stuart and Marla Huesers married in 1988 and had three children.' Stuart filed for separation from bed and board in November 1994, and in…