Sims v. Sims

Supreme Court of North Dakota · 2021 · Property
2021 ND 167 (2021)
Updated
propertydomestic violence protection orderclearly erroneous standardfactual findingsappealN.D.C.C. § 14-07.1-02N.D.R.App.P. 35.1(a)(2)

Facts

A domestic violence protection order was entered against Earl Sims in December 2020. The order was for two years. On appeal, Earl Sims argued the evidence presented at the district court hearing did not support the protection order. The opinion does not describe the underlying conduct in further detail.

Issue

Whether the evidence presented at the district court hearing was sufficient to support the two-year domestic violence protection order entered against Earl Sims, such that the district court's findings should be upheld on appeal.

Rule

In domestic violence proceedings under N.D.C.C. § 14-07.1-02, the district court's factual findings are reviewed under the clearly erroneous standard.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

  • The court's holding and reasoning
  • Doctrine tests, pitfalls & exam hypotheticals
  • 10 practice questions + 4 AI-graded essays on this case
Sign up free to see more →
Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Fargo, a district court held an evidentiary hearing on Lena Ortiz’s petition for a domestic violence protection order against Marcus Bell. The court issued a two-year order, and Marcus appeals, arguing the judge should have believed his witnesses instead of Lena’s.

What standard should the appellate court apply to the district court’s factual findings?

Explanation. The governing rule is that factual findings made by the district court in domestic violence proceedings under N.D.C.C. § 14-07.1-02 are reviewed under the clearly erroneous standard. A challenge that the judge should have credited different witnesses attacks factual findings, not a pure legal issue, so de novo review does not apply.