Eikom v. Eikom, 974 N.W.2d 387

Brittany Williamson and Chase Eikom divorced in 2018; Williamson was awarded primary residential responsibility and Eikom initially had supervised parenting time.
In February 2020 the parties removed the supervision requirement but did not set a fixed parenting schedule because of Eikom’s variable work schedule.
In July 2021 Eikom moved to amend the parenting plan seeking every-other-weekend time, alternating major holidays, and two consecutive months of summer parenting time.
Williamson agreed to every-other-weekend time but opposed full holiday/extended-summer proposals; she asked that Eikom’s time be reduced to one weekend per month if he missed four weekends in a year and that extended summer time be granted only after one year of consistent use.
After a September 2021 evidentiary hearing, the district court granted every-other-weekend parenting time, limited holiday time (Father’s Day, his birthday, and alternating Memorial/Labor Day), imposed the four-weekend-miss threshold (missing four weekends in a year reduces time to one weekend/month), and provided a graduated summer expansion if Eikom goes one year without missing four weekends.
Eikom appealed, arguing the court erred by (1) denying major-holiday and full summer visitation and (2) imposing the reduction condition tied to missed weekends without adequate rationale.

Issue	Plaintiff's Argument (Williamson)	Defendant's Argument (Eikom)	Held
Whether district court erred by denying all major-holiday and full summer visitation	Williamson argued child should be with parent who celebrates holidays; cited Eikom’s lack of holiday observance and instability to justify limited holiday and conditional summer time	Eikom argued alternating holidays and extended summer time are customary and Dschaak requires explanation when such customary time is denied	Affirmed — court gave factual explanations (Eikom does not celebrate holidays; concerns about job/housing instability) and findings are supported by evidence, not clearly erroneous
Whether the court erred in reducing parenting time if Eikom misses four or more weekends in a year (and whether sufficient rationale was provided)	Williamson argued the condition protects child stability and encourages consistent use of awarded time	Eikom argued the requirement lacked rationale and penalizes the parent and harms the child; he claimed the court speculated	Affirmed — court could discern rationale from the record (concerns about Eikom’s past instability); implied findings were permissible and the graduated approach was in child's best interest

Wigginton v. Wigginton, 692 N.W.2d 108 (N.D. 2005) (standard of review for parenting-time findings and best-interests focus)
Dschaak v. Dschaak, 479 N.W.2d 484 (N.D. 1992) (extended summer visitation is customary and denial requires explanation)
Loll v. Loll, 561 N.W.2d 625 (N.D. 1997) (appellate courts may rely on implied findings when the record permits)
In re N.C.M., 834 N.W.2d 270 (N.D. 2013) (parenting-time awards are governed by child’s best interests; parenting-time presumptively beneficial)
Bertsch v. Bertsch, 710 N.W.2d 113 (N.D. 2006) (best-interests standard governs parenting-time awards)
Hendrickson v. Hendrickson, 603 N.W.2d 896 (N.D. 2000) (parenting time is a right of the child and presumed beneficial)