In John E. v. Andrea E., the supreme court ruled the trial court abused its discretion in a child custody modification action when it excluded testimony by the child’s psychologist. A couple of years after the mother was granted primary physical and sole legal custody of their 12 year old daughter, the mother repeatedly hit her daughter as punishment. After the assault, the father took custody of the daughter pending the outcome of the custody modification action. A couple of months after the incident and shortly before a hearing on custody modification, the father took the daughter to see a psychologist. The psychologist was scheduled to testify at the hearing, but the trial court excluded the evidence because the visit was driven by litigation and overstepped the father’s legal authority. The supreme court reversed, holding the trial court had abused its discretion by excluding the psychologist’s testimony. The supreme court found the trial court excluded the psychologist’s testimony as a sanction for the father overstepping his legal authority. Instead, the trial court should have primarily been concerned with the with the daughter’s best interest. Reversing the trial court, the supreme court held the trial court abused its discretion in a child custody modification action when it excluded testimony by the child’s psychologist.
 445 P.3d 649 (Alaska 2019).