Slip opinions decided 2026 — North Dakota Reports

When a container has been previously opened by a government agent under lawful authority, and there is no substantial likelihood its contents have changed, a warrantless search of that container by law enforcement does not violate the Fourth Amendment of the United States Constitution or Article I, Section 8 of the North Dakota Constitution. Law enforcement officers are legally present in a home when the occupant consents to their entry

An order from a district court granting a motion to disqualify an attorney is not appealable under N.D.C.C. § 28-27-02(3) or the collateral order doctrine. Supervisory jurisdiction may be exercised to review an order granting a motion to disqualify an attorney because a civil litigant has a protected interest in counsel of the litigant's choice, and an appeal from a final judgment is not an adequate remedy for erroneous disqualification. When a district court finds a lawyer-client relationship between an attorney and a company based on objective manifestations, including providing legal advice to the company's officers and employees, the district court does not abuse its discretion in disqualifying the attorney under N.D.R. Prof. Conduct 1.7(a)(1) if the attorney represents clients on both sides of the litigation. A district court commits legal error by concluding an attorney has a lawyer-client relationship with a company solely because the attorney signed and prosecuted derivative claims brought by a shareholder on behalf of the company. An error is harmless if it does not affect the outcome of the case or a party's substantial rights.

A party does not have a right to appeal if there is no final judgment or proper N.D.R.Civ.P. 54(b) certification.

The mandate rule, a more specific application of law of the case, requires the district court to follow pronouncements of an appellate court on legal issues in subsequent proceedings of the case and to carry the appellate court's mandate into effect according to its terms. An appellate court retains authority to decide whether the district court on remand fully carried out terms of its mandate.

In an appeal challenging the sufficiency of the evidence, we look only to the evidence and reasonable inferences most favorable to the verdict to ascertain if there is substantial evidence to warrant the conviction. A conviction rests upon insufficient evidence only when, after reviewing the evidence in the light most favorable to the prosecution and giving the prosecution the benefit of all inferences reasonably to be drawn in its favor, no rational fact finder could find the defendant guilty beyond a reasonable doubt. A conviction may be justified on circumstantial evidence alone if the circumstantial evidence has such probative force as to enable the trier of fact to find the defendant guilty beyond a reasonable doubt. A verdict based on circumstantial evidence carries the same presumption of correctness as other verdicts. Jury instructions are reviewed as a whole to determine if they correctly and adequately inform the jury. Selecting and considering only a part of the instructions is not proper. An error in a jury instruction provides grounds for reversal only when the instructions as a whole are erroneous, relate to a central subject in the case, and affect the defendant's substantial right.

Appellate briefs must include references to the record and must cite to the record showing that issues were preserved for review. This Court will not consider arguments that are not adequately articulated, supported, and briefed, and will not engage in unassisted searches of the record for evidence to support a party's position. An information may be amended any time before verdict if no additional or different offense is charged. An amendment expanding the date range of an alleged offense does not constitute charging a different or additional offense when the essential elements remain unchanged. Section 12.1-02-02(2), N.D.C.C., is only applicable to Title 12.1, and the willful culpability level will not be read into other chapters unless the legislature specifically states as such.

Rule 11(a)(2), N.D.R.Crim.P., addresses conditional guilty pleas and requires: (1) the defendant, any defendant's attorney, and the prosecuting attorney consent in writing to the conditional plea; (2) the court accept the conditional plea and enter an order; and (3) the judgment specify the plea is conditional. Temporary remand is warranted for the district court's determination whether the plea was conditional and, if so, entry of an order and judgment consistent with the requirements of N.D.R.Crim.P. 11(a)(2).

The use of extended family members for childcare does not amount to a material change in circumstances unless it can be shown the arrangement has a detrimental effect on the children. A moving party must present competent evidence establishing a causal connection between alleged problems and the other parent's parenting. Merely alleging without support that problems stem from the other parent's parenting style is insufficient to establish a material change of circumstances. An isolated incident does not automatically mandate a finding of material change in circumstances, even when the incident involves potential endangerment to a child's physical or mental health.

The Fourth Amendment has drawn a firm line at the entrance to the house. Absent exigent circumstances, that threshold may not reasonably be crossed without a warrant. The location of a home's threshold is not always clear. Police may not enter a private enclosed entrance when there is a more direct alternative access designated for public use. An enclosed area may sometimes be the most direct access to a home's threshold and designated for public use.

A criminal judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(7).

Individuals who have been convicted of certain felony offenses are prohibited from owning a firearm or having one in possession. Under N.D.C.C. § 62.1-01-01(11), to obtain a conviction based on constructive possession, the State must prove the person had the power and intention to exercise control. Actual possession, on the other hand, may be proven by establishing direct physical control. The offense is no longer exclusively a strict liability offense, but it also does not always require proof of intent. Under N.D.C.C. § 62.1-01-01(3), a "firearm" is defined as any device that expels or is readily capable of expelling a projectile by the action of an explosive. This definition requires the State to prove a gun is functional. Direct evidence is not required; functionality may be proved by the surrounding facts and circumstances, including testimony from lay witnesses. Caselaw has not established a clear or obvious legal rule as to what constitutes sufficient evidence to prove a handgun is able to expel or readily capable of expelling a projectile.

A district court judgment denying application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(6) and (7).

A district court order denying an application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(4).

Under N.D.R.Civ.P. 3 a civil action is commenced by the service of a summons. Rule 3, N.D.R.Civ.P., allows the defendant to file the complaint in district court. Rule 3, N.D.R.Civ.P., differs from Fed.R.Civ.P. 3, which requires filing of a complaint to commence an action. Under N.D.R.Civ.P. 5, unless otherwise authorized by rule or statute, a party seeking to file an initiating pleading must provide proof that the pleading was served under Rule 4. Failure to file proof that the initiating pleading was filed is subject to N.D.R.Civ.P. 61 harmless error analysis. Prosecutors may be entitled to either absolute or qualified immunity from civil liability under 42 U.S.C. § 1983 for actions undertaken in accordance with their official duties. Prosecuting attorneys are considered quasi-judicial officers entitled to absolute immunity granted judges when their activities are intimately associated with the judicial phase of the criminal process. The prevailing party of a frivolous action shall be awarded attorney's fees under N.D.C.C. § 28-26-01(2).

The subject matter of a contract is governed by relevant statutory law. This general principle does not operate to transform an action based on statutory rights into a contract claim. A claim for unjust enrichment may be grounded in contract or tort law. Whether a claim for unjust enrichment sounds in tort or contract depends upon the factual basis underlying the claim. When the unjust enrichment allegations are predicated on tortious conduct, such as misrepresentation or fraud, the claim is properly characterized as one arising in tort.

A child's home state under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) is one in which a child has lived with a parent or a person acting as a parent for at least six months immediately before the commencement of a child custody proceeding. N.D.C.C. § 14-14.1-01(6). When North Dakota is not a child's home state, the UCCJEA still permits a North Dakota court to assume jurisdiction over a child custody proceeding in several circumstances, including when: (1) no other courts have home state jurisdiction; (2) no other courts with home state jurisdiction have declined jurisdiction on the ground North Dakota was the more appropriate forum; and (3) no other courts with jurisdiction (whether home state or otherwise) have declined jurisdiction on the ground that North Dakota was the more appropriate forum. N.D.C.C. § 14-14.1-12(1)(d).

A district court order denying a petition to terminate parental rights and for adoption is summarily affirmed under N.D.R.App.P. 35.1(a)(2)

A district court judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(7) and (8).

Rule 11, N.D.R.Crim.P., does not require courts to specifically address a defendant's age, education, mental capacity, background, or experience during the plea colloquy. Courts have no duty under Rule 11 to inquire about or rule out potential affirmative defenses before accepting a guilty plea. A guilty plea generally waives all non-jurisdictional claims and defenses, including constitutional, procedural, and statutory defenses. Rule 11(b)(3) requires the court to determine a factual basis exists before entering judgment on a guilty plea. The factual basis must satisfy all elements of the charged crime and be sufficiently precise and specific on the record. Even when a Rule 11 violation constitutes obvious error, the defendant must demonstrate the error affected substantial rights. A sentence within the statutory range and the range contemplated in the plea agreement is generally not grossly disproportionate under Eighth Amendment analysis.

NDIC is a creature of statute and only has the authority expressly granted by the legislature or necessarily implied from the legislature's express grant of authority. Section 38-08-04(1)(c), N.D.C.C., provides NDIC authority to allocate oil and gas production from an overlapping spacing unit to an underlying base spacing unit. NDIC failed to regularly pursue its authority when issuing the order allocating oil and gas production from an overlapping spacing unit to an underlying base spacing unit because it failed to modify the existing pooling orders under N.D.C.C. § 38-08-07, and failed to follow statutory procedures. An NDIC order allocating oil and gas production from an overlapping spacing unit to an underlying base spacing unit is vacated.

A district court's order denying a motion to change venue is summarily affirmed under N.D.R.App.P. 35.1(a)(4).

A juvenile court order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

A juvenile court order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

A district court can deviate upward from the presumptive child support guideline amount if it is in the best interest of a child and one or more of the enumerated criteria under N.D. Admin. Code § 75-02-04.1-09(2) is met. A district court's findings explaining why an upward deviation is in the best interest of a child, and explaining the amount of an upward deviation, are explicit enough if the Court is able to understand from them the factual basis for the district court's determination. The mandate rule does not permit a party to relitigate issues which were resolved in a first appeal, and requires a district court to follow the pronouncements of an appellate court within the limits of a remand.

To establish a due process violation based on pre-indictment delay, a defendant must demonstrate actual prejudice. Similarly, to establish a due process violation based upon the State's failure to preserve evidence, a defendant must demonstrate actual prejudice. When the State fails to preserve evidence that was at one point in the State's possession, a defendant must also present evidence of bad faith, meaning the State deliberately destroyed evidence with the intent to deprive the defense of information. Mere speculation that unpreserved evidence might have been exculpatory is not enough to show actual prejudice.

A party does not have a right to appeal if there is no final judgment or order under N.D.C.C. § 28-27-01. A dismissal for lack of personal jurisdiction is presumed to be without prejudice.

The juvenile court's order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

The district court's eviction judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(1), (7) and (8).

The failure to display a license plate under Dickinson Municipal Code § 58-705 constituted a noncriminal violation. The district court order did not clearly err in designating the defendant a vexatious litigant. The required findings, filings, and notices for identification of a vexatious litigant provide sufficient procedural safeguards to prevent constitutional violations. The citation to non-existent cases in an appellate brief is a violation of N.D.R.App.P. 28(l), which exposes the filing party to the imposition of sanctions for their misconduct.

This Court will only vacate a district court's sentencing decision if the court acted outside statutorily prescribed limits or substantially relied on an impermissible factor. A district court may tailor probation conditions to each case's particular facts and circumstances as long as the conditions are reasonably necessary to ensure the defendant will lead a law-abiding life or to assist the defendant to do so. The constitutional right to parent is not without limits. Courts may impose sentences that may conflict with a parenting order when imposing such sentence serves other penological interests.

Arguments that are not adequately articulated, supported, and briefed on appeal are not considered and are deemed waived. Parenting time between a parent without primary residential responsibility and a child is presumed to be in the child's best interests and that it is not merely a privilege of the parent, but a right of the child. Parenting time should be restricted only upon a showing by a preponderance of the evidence that unrestricted parenting time is likely to endanger the child's physical or emotional health.

A juvenile court must comply with the Indian Child Welfare Act ("ICWA") in termination of parental rights proceedings where the court knows or has reason to know an Indian child is involved. To determine whether ICWA applies in a termination of parental rights proceeding, a juvenile court must make an initial inquiry as to whether an Indian child is involved.

A criminal judgment for a terrorizing conviction is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

Under N.D.C.C. § 12.1-32-02.1(1)(a), a term of imprisonment must be imposed when, in the course of committing an offense, the offender threatens another with imminent bodily injury using, or through the use or means of, a firearm.

An attorney at a public meeting explaining the legal position of a governing body did not waive the governing body's ability to enter an executive session. A governing body can discuss the value requested by an adverse party without waiving the ability to discuss other adverse fiscal impacts in an executive session. A party seeking disclosure of records withheld as exempt from open records laws does not have a due process right to participate in an in camera review or to access the records for the purpose of fully arguing why the party should have access to them. A district court abuses its discretion if it grants a public entity summary judgment dismissal of an open meetings violation claim without reviewing in camera the short executive session recording that the public entity claims is exempt from disclosure under the attorney consultation exemption.

A criminal judgment entered after a jury convicted the defendant of simple assault on a correctional officer is summarily affirmed under N.D.R.App.P. 35.1(a)(3) and (7).

An order denying an application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(2), (7), and (8).

A juvenile court order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

An appeal from an order terminating parental rights must be taken by filing a notice of expedited appeal with the clerk of the supreme court within 30 days after entry of the order. An order, which is complete, which if final, and which does not anticipate or direct further action, is appealable. Absent a timely appeal or retention of custody of the child, an order terminating parental rights may not be questioned by any person, including the petitioner, in any manner, or upon any ground.

The Fourth Amendment of the United States Constitution and Art. I, § 8, of the North Dakota Constitution protect individuals against unreasonable searches and seizures. When an individual reasonably expects privacy in an area, the government, under the Fourth Amendment, must obtain a search warrant unless the intrusion falls within a recognized exception to the warrant requirement. One exception to the warrant requirement is the automobile exception. Under the automobile exception, law enforcement may search for illegal contraband without a warrant when probable cause exists. Probable cause to search exists if it is established that certain identifiable objects are probably connected with criminal activity and are probably to be found at the present time at an identifiable place. Probable cause demands not that an officer be sure or certain but only that the facts available to a reasonably cautious man would warrant a belief that certain items may be contraband or stolen property or useful as evidence of a crime. A police officer may draw inferences based on his own experience in deciding whether probable cause exists.

A district court's findings in adoption cases are reviewed under the clearly erroneous standard. A district court's denial of an adoption petition is reviewed for an abuse of discretion. The district court found "red flags" surrounded the adoption, and finding adoption was not in K.J.K.'s best interest was not clearly erroneous. The court did not abuse its discretion in denying the adoption petition.

A party's failure to comply with the contractual requirements can waive the party's ability to enforce the contractual requirements. A teacher's separate contract for work performed outside the regular school day, that provides separate pay and different responsibilities from the duties of their teaching contract, is extracurricular.

The Court will not consider an argument under obvious error review unless the appellant briefs the issue under the obvious error standard of review. The district court did not abuse its discretion in admitting evidence of a prior conviction that was an element of the charged offense.

A district court may determine a child support obligation based on earning capacity rather than earnings history. The presiding judge of the judicial district, not the judge sought to be disqualified, determines the validity and timeliness of a demand for change of judge under N.D.C.C. § 29-15-21. However, when a demand for change of judge is untimely filed under N.D.C.C. § 29-15-21(2), the error in having the wrong judge rule on the demand is harmless under N.D.R.Civ.P. 61.

A default judgment entered after the district court dismissed the answer and counterclaim as a discovery sanction is affirmed. When a party fails to properly raise an issue or argument before the district court, it may not do so for the first time on appeal. Rule 60(b), N.D.R.Civ.P., is the exclusive means for opening a default judgment. When a default judgment is appealed, rather than a district court's order regarding a N.D.R.Civ.P. 60(b) motion to vacate the default judgment, we review the default judgment to determine if irregularities appear on the face of the judgment.

An admission of nonpayment of some, if not all, claimed obligations owed under a judgment can be enough to support a contempt finding. Remedial sanctions for contempt cannot be broader than necessary to address the specific contemptuous conduct, that is, the sanctions must be compensation for actual losses caused by the contempt or have a nexus to either compelling future compliance.

The lack of a remedy for a statutory violation does not, in and of itself, render a statute ambiguous. Instead, it signals an intent by the legislature for the courts to apply a prejudice standard to a statutory violation.

District court did not clearly err in finding there was a material change in circumstances justifying modification of parenting time where parent with residential responsibility interfered with parenting time and was unwilling to accommodate reasonable exchange plans, the children and noncustodial parent desired to spend more time together, and the judgment contained uncertain exchange times, which caused conflict for the parties. Under N.D.R.Ct. 8.13(a), the district court may conduct an in chambers interview of a child in a parenting time proceeding only if the parents consent. Under N.D.C.C. § 14-09-06.3 and N.D.R.Ct. 8.6, the parenting investigator must file and serve her report before the evidentiary hearing, and must be available to testify at the hearing. A court abuses its discretion when it relies on the parenting investigator's report without having first provided the parties notice and an opportunity to cross-examine the parenting investigator on her report at the hearing.

A district court judgment awarding an earnest money deposit to the seller and dismissing the buyers' counterclaims for declaratory judgment, breach of contract, unjust enrichment, and conversion is affirmed. Several contracts relating to the same matters between the same parties and made as parts of substantially one transaction are to be taken together. N.D.C.C. § 9-07-07. When part of a contract is drafted under the special directions of the parties and the remainder is copied from a standard form, the specially drafted part controls over the standard form language; if the two are absolutely repugnant, the form language must be disregarded. N.D.C.C. § 9-07-16. When a contract contains conflicting provisions, the resulting uncertainty is construed against the party who drafted the contract. N.D.C.C. § 9-07-19. The later-in-time principle, under which inconsistent provisions in a later contract supersede those in an earlier contract, does not apply where the earlier agreement is expressly incorporated into the later one. An argument that a party breached the obligation of good faith during contractfor-deed negotiations does not affect the disposition of earnest money that had already become non-refundable before the allegedly objectionable conduct occurred.

Judgments amending parenting time and payment of child's medical expenses, and finding abusive litigation are summarily affirmed under N.D.R.App.P. 35.1(a)(2)

An appeal from a district court judgment is dismissed because the appeal was untimely. The court's amended judgment inserting the amount of costs awarded in the judgment did not toll the time to appeal.

The district court's judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(1). When requesting more than token attorney's fees under N.D.R.App.P. 38, the prevailing party should submit documentation of the expenses incurred on the appeal. Without such documentation, the Court may consider awarding a fixed amount.

A losing party cannot, after a civil jury trial, raise the issues of sufficiency of the evidence or weight of the evidence for the first time on appeal. Jury instructions are reviewed as a whole to determine if they fairly and adequately advise the jury of the law. Inadequately briefed issues are not reviewed on appeal. Judges, whether trial or appellate, are not ferrets obligated to engage in unassisted searches of the record for evidence to support a litigant's position. The district court has sole discretion under N.D.C.C. § 28-26-06(5), to award expert witness fees that are reasonable plus actual expenses.

When a court summarily dismisses an application before the State responds, the dismissal is treated as analogous to dismissal of a civil complaint under N.D.R.Civ.P. 12(b) for failure to state a claim upon which relief can be granted. District courts may consider applications for postconviction relief discovered beyond the two-year statutory limitation if the petitioner alleges the existence of newly discovered evidence which would establish the petitioner did not engage in the conduct for which petitioner was convicted. When applications for postconviction relief assert newly discovered evidence under the exception to the statute of limitations, district courts must apply the four-prong test to determine if the evidence constitutes newly discovered evidence.

A district court's divorce judgment is summarily affirmed under N.D.R.App.P 35.1(a)(2), (4), and (7).

When exercising their discretion to impose sanctions, courts should consider the impact of the imposed sanction on innocent third parties. While district courts retain broad authority to sanction discovery violations, that authority is necessarily constrained by the overriding obligation to consider all relevant evidence bearing on the child's best interests. When a court imposes sanctions in a case involving residential responsibility and parenting time, the court must consider whether the sanction precludes the court from receiving evidence bearing on the child's best interests. Under the facts of this case, the court abused its discretion by imposing an evidentiary sanction that barred a parent from presenting any evidence at a trial involving residential responsibility and parenting time.

Rule 11(a)(2), N.D.R.Crim.P., addresses conditional guilty pleas and requires: (1) the defendant, any defendant's attorney, and the prosecuting attorney consent in writing to the conditional plea; (2) the court accept the conditional plea and enter an order; and (3) the judgment specify the plea is conditional. Temporary remand is warranted for the district court to correct the judgment to conform with the requirements of N.D.R.Crim.P. 11(a)(2).

A two-pronged test is used when determining whether an order is appealable. First, the order appealed from must meet one of the statutory criteria of appealability set forth in N.D.C.C. § 28-27-02. If it does not, our inquiry need go no further and the appeal must be dismissed. If it does, then Rule 54(b), N.D.R.Civ.P., if applicable, must be complied with. An "automatic stay" under N.D.C.C. § 51-07-01.1(3) is appealable under N.D.C.C. § 28-27-02(3). The authority to issue a supervisory writ is discretionary and we decide whether to exercise our supervisory jurisdiction on a case-by-case basis.

The district court's amended criminal judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(7).

A juvenile court order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Under the Uniformed Services Former Spouses' Protection Act 10, U.S.C. § 1408, as interpreted in Howell v. Howell, 581 U.S. 214 (2017), an indemnification provision requiring a veteran to compensate a former spouse for retirement pay waived in favor of disability benefits is void and unenforceable, regardless of whether the parties agreed to it. A district court's award of spousal support calculated to restore a former spouse's lost share of waived retirement pay is merely a semantic reframing of the prohibited division of disability pay and is preempted by federal law.

Only judgments and decrees which constitute a final judgment of the rights of the parties and certain orders enumerated by statute are appealable. For each issue, the appellant must cite to the record showing that the issue was preserved for review or state the grounds for seeking review of an issue not preserved. Under N.D. Sup. Ct. Admin. R. 58(3)(a), the presiding judge, on the court's own motion, may designate a litigant as a vexatious litigant. Procedural safeguards are contained within N.D. Sup. Ct. Admin. R. 58 providing for a specific vexatious litigant definition, appropriate notice, requisite court findings, and the pre-filing order contents. The Court reviews an order finding a litigant vexatious for an abuse of discretion. If an appeal is frivolous, the Court may award just damages and single or double costs, including reasonable attorney's fees.

An officer must administer the Miranda warning when a person is subject to custodial interrogation. A suspect is in custody when there is a formal arrest or restraint on the suspect's freedom of movement to the degree associated with a formal arrest. The "automobile exception" to the Fourth Amendment's warrant requirement allows law enforcement officers to search a vehicle for illegal contraband without a warrant upon establishing probable cause the vehicle contains contraband. Allowing a drug-sniffing dog to sniff a vehicle is not a search within the meaning of the Fourth Amendment. A drug-sniffing dog indicating the presence of a controlled substance establishes probable cause. Unrelated inquiries are permitted during a stop as long as they do not prolong the stop and extend the time the individual is detained. A stop may be prolonged only if the officer has reasonable suspicion to justify detaining the individual for inquiries unrelated to the stop.

The district court's decision on a new trial motion is reviewed under the abuse of discretion standard. A court abuses its discretion when it acts arbitrarily, unconscionably, or unreasonably, when its decision is not the product of a rational mental process leading to a reasoned determination, or when it misapplies or misinterprets the law. An abuse of discretion is never assumed; the burden is upon the party seeking relief to affirmatively establish it. Even if evidence of domestic violence does not rise to the level triggering the rebuttable presumption against awarding perpetrating parent residential responsibility under N.D.C.C. § 14-09-06.2(1)(j), the evidence must be considered if it is credible. A district court does not abuse its discretion by requiring a witness to testify from memory, without the assistance of notes, if the witness does not indicate a need for the notes, such as to refresh recollection. Self-represented litigants are not granted relaxed judicial standards or greater judicial assistance than litigants represented by counsel. When a dispositive motion fully resolves all pending claims, a district court need not address other pending motions that are rendered moot by that final disposition, regardless of when those motions were filed.

A district court's findings must be specifically detailed to explain the factual basis for its decision to include individuals as protected parties under domestic violence protection orders. A district court abuses its discretion when it fails to sufficiently explain the court's rationale for the domestic violence protection order's duration.