Although Morgan asserts on appeal that the bifurcation violated her due process rights, she has failed to point to any constitutional requirement that a hearing to determine custody modification necessarily take a particular form. But the holding in Abbott is not inconsistent with the bifurcation procedure. Morgan's challenge suggests that important evidence was excluded from the hearing because of the bifurcation. She has, however, failed to point to or challenge any specific evidentiary rulings. If evidence relevant to the endangerment or impairment of the children's health and development was excluded, those specific adverse rulings could have been raised on appeal.
Public policy favors the efficient use of judicial resources.
For these reasons and because the statute requires a showing of endangerment or impairment before custody modification is allowed, the district court did not err in bifurcating the evidentiary hearing. As between Morgan, the children's mother, and Patricia Kunze, Morgan would be entitled to custody as a matter of law. The record supports that finding. Morgan's assertion that the district court erred by awarding de facto custody to Patricia Kunze is unsupported. III Minn. Stat.