Kulbacki v. Michael

by
In a proceeding relating to the modification of grandparent visitation, the termination of a parent's rights is a material change in circumstances. Amanda Kulbacki appealed a district court order denying her motion to terminate Shawn Coulter's grandparent visitation with Kulbacki's minor child and amend the child's birth certificate. The North Dakota Supreme Court reversed, concluding as a matter of law, the termination of Nicholas Michael's parental rights was a material change in circumstances and Coulter (Michael's mother) was not able to establish a basis to have visitation under the facts of this case. The Court remanded for briefing on the district court's jurisdiction to order the department of vital statistics to amend the child's birth certificate upon termination of parental rights. View "Kulbacki v. Michael" on Justia Law