MESCHKE, Justice.
Elizabeth Flemming appealed a decree placing primary physical custody of her son, Robert Jr., with his father, Robert Ryan. We consider the effect of a private judicial interview of a child witness without administering an oath, the effect of violence to property on the presumption against custody by a violent parent, and whether the evidence supported placement of primary custody of a five-year-old boy with his father. We affirm.
Robert...
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