Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Family Law
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The case revolves around the interpretation of the term "resources" as used in the criminal restitution statute, Minnesota Statutes section 611A.045, subdivision 1(a)(2). Specifically, the case examines whether the equity in a defendant's home, which he co-owns with his spouse, can be considered as a "resource" when awarding restitution. The appellant, Joshua Henry Baion Cummings (Baion), was convicted of one count of theft by false representation and was ordered to pay restitution. The district court considered the equity in Baion’s home as one of his resources when determining the amount of restitution. Baion appealed, arguing that the equity in a home owned with a non-defendant spouse cannot be considered a resource under the restitution statute. The Court of Appeals affirmed the district court's decision. The Minnesota Supreme Court also affirmed, holding that the term “resources” in the restitution statute unambiguously means useful and valuable possessions, and that home equity, even when the home is co-owned with a non-defendant spouse, may be such a possession. View "State v. Cummings" on Justia Law

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The Minnesota Supreme Court affirmed the decision of the lower courts to terminate a mother's parental rights due to her failure to appear for the final day of a multiple-day termination of parental rights trial. The mother, identified as S.T., had argued that the district court violated her procedural due process rights by refusing to reschedule the trial to allow her to testify, offer additional witnesses, and cross-examine witnesses. However, the Supreme Court found that S.T. failed to demonstrate that the outcome of the trial was materially affected by her absence. The Supreme Court noted that although S.T.'s absence was troubling, the district court's refusal to continue or reschedule the hearing did not automatically violate due process. The court concluded that S.T. did not make a sufficient case that her testimony or that of her proposed witnesses would have materially affected the outcome of the trial. Therefore, the court upheld the termination of S.T.'s parental rights. View "In the Matter of the Welfare of the Children of: G.A.H. and S.T., Parents" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals dismissing Appellants' appeal of the dismissal of their petition for permanent third-party custody of their great niece, K.J., holding that the court of appeals erred in dismissing the appeal for failure to timely serve the guardian ad litem with a notice of appeal under Minn. R. Civ. App. P. 103.01, subdivision 1.After Appellants filed their petition the district court appointed a guardian ad litem. A referee approved a stipulation of shared joint legal and physical custody of K.J. by Respondent, K.J.'s mother, and K.J.'s father. After a hearing, the court dismissed Appellants' petition for third-party custody. The court subsequently discharged the guardian ad litem, after which Appellants appealed. The court of appeals dismissed the appeal for failure to timely serve the guardian ad litem under Rule 103.01, subdivision 1. The Supreme Court reversed, holding (1) the guardian ad litem was no longer a party to the action once she was discharged by the district court; and (2) Rule 103.01, subdivision 1 does not require service of a notice of appeal on a former party whose dismissal is not itself the subject of the appeal. View "Blakey v. Jones" on Justia Law

Posted in: Family Law
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The Supreme Court reversed the judgment of the court of appeals upholding the district court's award of attorney fees based on conduct that occurred outside the context of litigation, holding that the district court exceeded the scope of its inherent authority when it awarded attorney fees.In this case arising from a post-dissolution, mediated settlement agreement between Appellant and Respondent regarding the treatment of a college savings account. The agreement required that the account be awarded to the parties' daughter when she turned twenty-one years old, but when their daughter reached that age Appellant took no action to transfer the account. Ultimately, after intervention on the part of the district court, the transfer became effective. Respondent moved for conduct-based attorney fees under Minn. Stat. 518.14. The district court granted the motion.. The court of appeals affirmed. The Supreme Court reversed, holding that the district court exceeded the scope of its inherent authority in awarding attorney fees because the award was not necessary to the performance of a judicial function. View "Buckner v. Robichaud" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the judgment of the court of appeals determining that the juvenile court had subject-matter jurisdiction over this case, rejecting Father's statutory interpretation argument about the interplay between the child protection and predatory offender registration statutes, and affirming the termination of Father's parental rights by the juvenile court, holding that Father was not entitled to relief on his claims of error.While Father was incarcerated for an offense that arose out of the same circumstances as an offense enumerated in the predatory offender registration statute Mother gave birth to H.Q., who was adjudicated as a child in need of protection or services. The juvenile court terminated Father's parental rights to H.Q. because of his conviction. The court of appeals affirmed the juvenile court's termination of Father's parental rights. The Supreme Court affirmed, holding that the juvenile court did not err in determining that clear and convincing evidence supported the statutory ground for termination in Father's case. View "In re Welfare of Child of S.B.G." on Justia Law

Posted in: Family Law
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The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the district court rejecting Wife's action against Husband seeking half of his retirement account or, alternatively, an equitable portion of the account, holding that the parties' omission of their largest asset from the dissolution decree made it impossible for the district court to determine whether the settlement was equitable.After the parties' marriage was dissolved through a joint petition for marriage dissolution Wife filed this action seeking half of Husband's retirement account. In objecting, Husband argued that he and Wife had intentionally omitted his retirement account from their joint petition pursuant to an unwritten side agreement. The district court concluded that the relief Wife sought was beyond the scope of a ** proper enforcement of clarification order and was time-barred to the extent it sought to reopen the decree. The court of appeals affirmed. The Supreme Court reversed, holding (1) district courts have the power to address omitted assets that fall outside the scope of the grounds set forth in Minn. Stat. 518.145, subd. 2 for reopening a dissolution decree; and (2) the parties' omission from the decree of their largest asset rendered it impossible for the district court to determine whether the settlement was equitable. View "In re Marriage of Pooley" on Justia Law

Posted in: Family Law
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The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court applying the endangerment standard of the child-custody modification statute, Minn. Stat. 518.18(d)(iv), to a noncustodial parent's motion for joint legal custody of the parties' child based on their prior stipulation to apply the statutory best-interests standard set forth in Minn. Stat. 518.18(d)(i), holding that the district court erred.The noncustodial parent's modification motion in this case was expressly predicated on section 518.18(d)(i), which provides that the statutory best-interests standard set forth at Minn. Stat. 518.17 applies if the parties previously agreed in a court-approved writing to the application of that standard. The district court denied the motion for custody modification without holding an evidentiary hearing. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by requiring the noncustodial parent to establish a prima facie case for a change in custody based on the statutory endangerment standard in section 518.18(d)(iv). View "Woolsey v. Woolsey" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the nonprecedential opinion of the court of appeals instructing the district court to consider whether Rebecca Bender presented newly discovered evidence warranting relief from a child support order, holding that the district court should have determined whether Bender's proffered evidence warranted relief.Years after marriage dissolution and child support proceedings between Bender and Peter Bernhard, Bender filed a motion to modify the child support termination order based on "newly discovered evidence" under Minn. Stat. 518.145, subd. 2(2) and Minn. R. Civ. P. 60.02. The district court denied the motion. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding (1) as may be just, a district court has discretion under section 518.145 to consider newly discovered evidence that arises after the court's underlying decision; and (2) the district court abused its discretion in finding that Bender's newly discovered evidence was not "new." View "Bender v. Bernhard" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the judgment of the district court in this case arising out of a dispute between the children of Lawrence and Phyllis Schwagerl over the disposition of assets owned by Lawrence's trust before his death, holding that the court of appeals erred in part.The assets in this case included undivided half-interests in more than 700 acres of farm real estate owned by the family, as well as Lawrence and Phillis's residence and surrounding yard. The district court determined (1) the Lawrence Trust agreement created a family trust upon Lawrence's death and that his undivided half-interest in the farm real estate was distributed to that trust, and (2) Phillis waived her right to Lawrence's undivided half-interest in the couple's personal residence at the time of his death by intentionally leaving ownership of that property within the family trust. View "In re Trust of Lawrence B. Schwagerl" on Justia Law

Posted in: Family Law
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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court finding that Mother's child was in need of protection or services, holding that the district court properly considered the allegations of the petition in this case and that Rice County proved the allegations by clear and convincing evidence.After Mother failed to appear at a pretrial hearing the County requested to proceed by default pursuant to Minn. R. Juv. Prot. P. 18. The district court granted the request and found that the child in this case was in need of protection or services. The court of appeals reversed, concluding that the juvenile protection rules do not allow for relief in a default proceeding based solely on the pleadings and that the evidence was insufficient to support the adjudication. The Supreme Court reversed, holding (1) the district court could not simply accept the allegations in the County's petition as true when Mother failed to appear for the pretrial hearing; (2) the unrequited witness testimony presented at the hearing established that the allegations of the petition were true and correct; and (3) the court did not err in finding that the child was in need of protection or services. View "In re H.G.D." on Justia Law

Posted in: Family Law