Krejci v. Krejci, 934 N.W.2d 179

Mark (paternal grandfather) obtained a 2016 Nebraska decree granting grandparent visitation: 17 consecutive summer days plus a weekend every 3 months.
In May 2018 a scheduled visit fell on the deceased father’s birthday; both children refused to go and Christina (mother) did not force them to attend.
Mark sued for civil contempt and interference with visitation; Christina filed to modify the decree.
The district court held a contempt hearing, found Christina did not willfully disobey the decree, and dismissed the contempt complaint.
In the same order the court (despite earlier dismissing Christina’s modification complaint as jurisdictionally improper) modified the decree to exclude the father’s birthday/anniversary and reduce summer visitation to 8 days.
Mark appealed the contempt dismissal and the modification; Christina attempted a cross-appeal but failed to comply with appellate cross-appeal form requirements.

Issue	Plaintiff's Argument (Mark)	Defendant's Argument (Christina)	Held
Whether Christina was in civil contempt for preventing the May 19 visit	Mark: Christina willfully interfered with visitation and should be held in contempt	Christina: Children refused on their own; she did not encourage or coerce them	Court: No contempt; evidence showed a singular event and no willful disobedience; dismissal affirmed
Whether the district court properly modified the visitation decree at the contempt hearing	Mark: Modification was improper because he lacked notice and opportunity to present modification-specific evidence	Christina: Modification was justified by children’s ages, activities, and desire to avoid father’s birthday	Court: Modification vacated for lack of notice and opportunity to be heard; portion reversed and vacated
Whether Christina’s cross-appeal is properly before the court	Mark: N/A	Christina: Raised modification-related arguments on cross-appeal	Court: Christina’s cross-appeal failed to meet Neb. Ct. R. App. P. § 2-109 requirements; merits not considered

Martin v. Martin, 294 Neb. 106 (sets three-part appellate standard in civil contempt: de novo law, clear error for facts, abuse of discretion for contempt/sanction)
Hossaini v. Vaelizadeh, 283 Neb. 369 (willfulness and clear-and-convincing standard for civil contempt)
Smeal Fire Apparatus Co. v. Kreikemeier, 279 Neb. 661 (civil contempt principles)
Hamit v. Hamit, 271 Neb. 659 (grandparent visitation governed by statute, historical context)
Pier v. Bolles, 257 Neb. 120 (common-law restriction on grandparent visitation rights)
Troxel v. Granville, 530 U.S. 57 (parental rights and third-party visitation context)
Moriarty v. Bradt, 177 N.J. 84 (importance of grandparent-grandchild relationship in visitation statutes)