North Dakota Century Code
N.D. Cent. Code § 14-20-47 (2026)
(612) Child as party - Representation
✓ current as of May 2026
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1. A minor child is a permissible party, but is not a necessary party to a proceeding under sections 14-20-36 through 14-20-58.
2. The court shall appoint a guardian ad litem to represent a minor or incapacitated child if the child is a party or the court finds that the interests of the child are not adequately represented.
Notes of Decisions
Cited in 2
cases, 2012–2012 · leading case: D.E. v. K.F., 825 N.W.2d 832 (N.D. 2012).
D.E. v. K.F., 825 N.W.2d 832 (N.D. 2012). “[¶ 23] Under these limited circumstances, we conclude the district court erred in failing to appoint a guardian ad litem for the child under N.D.C.C. § 14-20-47, and the district court on remand should appoint a guardian ad litem to represent the child’s interests in any further…”
State v. Wolfgram, 2012 ND 251 (N.D. 2012). “[¶23] Under these limited circumstances, we conclude the district court erred in failing to appoint a guardian ad litem for the child under N.D.C.C. § 14-20-47, and the district court on remand should appoint a guardian ad litem to represent the child’s interests in any further…”
— N.D. Cent. Code § 14-20-47(1) — 2 cases
D.E. v. K.F., 825 N.W.2d 832 (N.D. 2012). “[¶ 23] Under these limited circumstances, we conclude the district court erred in failing to appoint a guardian ad litem for the child under N.D.C.C. § 14-20-47, and the district court on remand should appoint a guardian ad litem to represent the child’s interests in any further…”
State v. Wolfgram, 2012 ND 251 (N.D. 2012). “[¶23] Under these limited circumstances, we conclude the district court erred in failing to appoint a guardian ad litem for the child under N.D.C.C. § 14-20-47, and the district court on remand should appoint a guardian ad litem to represent the child’s interests in any further…”
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