Missouri Court of Appeals, Eastern District / Nov 17, 2020
E.K.H.-G., Respondent, vs. R.C., III, Appellant.
R.C. III (Father) appealed the trial court's judgment granting E.K.H.-G (Grandmother) third-party custody of his daughter after the Mother's death. The trial court had prohibited Father from presenting evidence as a sanction for discovery violations. The appellate court reversed and remanded, holding that the trial court abused its discretion by imposing such a harsh sanction without finding prejudice to Grandmother or contumacious disregard by Father, and without considering lesser sanctions. The court emphasized the importance of hearing both parents' perspectives in child custody disputes.