Justia Minnesota Supreme Court Opinion Summaries

The common law governs provisions of an antenuptial agreement that do not fall within the safe harbor of Minn. Stat. 519.11(1), and the multifactor Kinney test is the common-law test applicable to antenuptial agreements. See In re Estate of Kinney, 733 N.W.2d 118 (Minn. 2007).Wife petitioned for dissolution and moved to set aside the antenuptial agreement she signed just before her marriage. The district court invalidated the agreement, concluding that it was procedurally unfair because Wife did not have an adequate opportunity to meet with legal counsel of her own choice and that it was substantively unfair and the time it was made and executed. The court of appeals affirmed on different grounds, concluding (1) to the extent the district court relied on Minn. Stat. 519.11 for evaluating procedural fairness, the court erred; (2) agreements that purport to distribute marital property, such as the agreement in this case, must be evaluated under the common law; and (3) the agreement was procedurally unfair. The Supreme Court affirmed after applying the Kinney factors to the entire agreement, holding that this agreement did not satisfy the common law test for procedurally fairness, and therefore, the agreement was invalid and unenforceable. View "Kremer v. Kremer" on Justia Law

In a proceeding to terminate parental rights that is governed by the Indian Child Welfare Act (ICWA) and the Minnesota Indian Family Preservation Act (MIFPA), qualified expert witness testimony is required to support the determination that continued custody of the child by the parent is likely to result in serious emotional or physical damage to the child.The district court terminated the parental rights of Mother and Father, concluding that ICWA and MIFPA applied to the proceedings and that the laws’ requirements had been satisfied. The court of appeals reversed in part, holding that the district court erred in failing expressly to find under ICWA and MIFPA that continued custody of the child by the parent was likely to result in serious emotional or physical damage to the child. On appeal, the district court stated as much in a one-sentence addendum to its findings of fact and conclusions of law. The court of appeals affirmed the district court’s termination decision. The Supreme Court reversed in part, holding that the district court erred in terminating Father’s parental rights because the qualified expert witness’s testimony did not support the court’s determination that continued custody of the children by Father would likely result in serious damage to the children. View "In re Welfare of Children of S.R.K. & O.A.K." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court’s denial of Father’s request for additional parenting time to provide before- and after-school child care for the parties’ son, K.T., while Mother was working.The parties stipulated to joint legal and physical custody with equal parenting time, and the district court approved the parenting time. Ten days later, Father filed a motion for additional parenting time to provide child care for K.T. before and after school on Mother’s parenting days. The district court denied the request. Father appealed, arguing that the district court based its decision on irrelevant or repealed factors and that the district court erred by failing to make detailed findings on the newly amended best-interest factors listed in Minn. Stat. 518.17(1)(a). The court of appeals affirmed. The Supreme Court affirmed, holding (1) parenting time modifications under Minn. Stat. 518.175(8) do not require the same detailed, specific findings that an order establishing custody or parenting time now requires; and (2) the district court did not rely on factors that were either repealed or irrelevant. View "Hansen v. Todnem" on Justia Law

The deadline for an appeal in a juvenile protection proceeding is based on the district court’s service of notice by mail. In this case, because the appeal was filed by that deadline, the court of appeals erred in dismissing the appeal as untimely. Here, the district court terminated L.A.’s parental rights after allegations were made that L.A. was in need of protection or services. L.A. filed a notice of appeal. The court of appeals dismissed the appeal as untimely. The Supreme Court vacated the opinion of the court of appeals, holding that L.A.'s appeal was timely filed because nothing in the plain language of the rules told him that he could not rely on the service upon him by mail when calculating the deadline for filing his appeal. View "In re Welfare of Child of R.K." on Justia Law

The district court’s denial of Mother’s motion to “reinstate” joint custody of the parties’ children, though appealable, erroneously modified custody without complying with the requirements of Minn. Stat. 518.18.After dissolving their marriage, Mother and Father agreed to share joint legal and physical custody of their two children. The district court adopted the parties’ agreement. Thereafter, the district court issued a series of orders granting Father temporary sole custody of the children. When the parties did not resume joint physical custody more than one year later, Mother moved to reinstate joint custody. The district court denied the motion. The court of appeals affirmed the district court’s order. The Supreme Court reversed, holding that the district court erred when it modified the custody arrangement established by the judgment and decree. The court remanded the case to reinstate the original custody order or, upon a motion to modify, for an evidentiary hearing. View "Crowley v. Meyer" on Justia Law

In 2012, Wife filed a petition to dissolve her marriage to Husband. The court approved the parties’ stipulation and entered partial final judgment dissolving the marriage. The stipulation, however, did not address Wife’s request for spousal maintenance. After a trial on the issue, the district court declined to award maintenance to Wife, determining that Wife could reallocate the investment assets equitably distributed to her in the property settlement to produce sufficient income to meet her reasonable monthly expenses. The court of appeals affirmed. The Supreme Court reversed and remanded, holding (1) the district court did not abuse its discretion in taking into account the income-earning potential of the assets that Wife received in the equitable distribution of marital property; but (2) under the circumstances, the district court’s obligation to consider the tax consequences of the reallocation required remand. View "Curtis v. Curtis" on Justia Law

The district court ordered Father to pay monthly child support. Dakota County was a party to the proceeding because Mother had applied for non-public assistance child support services. Father later retired due to disability and began receiving Social Security benefits. As a result, Mother began receiving derivative Social Security benefits on behalf of the children. Father moved to modify his child support obligation. The child support magistrate granted Father’s motion in part and offset his prospective child support obligation by the derivative Social Security benefits received by Mother. Both parties sought review. The district court concluded Father was entitled to credit for the derivative Social Security benefits received by Mother at the time Mother began receiving derivative Social Security benefits but before Father served notice of the motion to modify. The Supreme Court reversed, holding that a modification of a child support order is retroactive to the date of service of the notice of motion to modify. View "In re Dakota County" on Justia Law

Prior to his death and after consulting a lawyer about divorcing Wife, Husband changed the beneficiary on his term life insurance policy from Wife to Respondents, his parents and sister. Less than four months before Husband’s death, Wife petitioned for dissolution of marriage to Husband. Following Husband’s death, the district court dismissed the dissolution proceeding. Wife subsequently filed suit against Respondents, alleging that Husband’s transfer violated Minn. Stat. 518.58(1)(a), which prohibits the transfer of “marital assets” by a party who contemplates commencing a marriage dissolution. The district court granted summary judgment to Respondents. The court of appeals affirmed, holding that section 518.58(1)(a) did not apply to Wife’s claim because her dissolution proceeding abated upon Husband’s death and the statute applies only in current dissolution proceedings. The Supreme Court affirmed, holding that because the language of section 518.58(1)(a) limits the statute’s application to pending dissolution proceedings, the statute did not provide Wife, who was no longer a party to a marital dissolution proceeding, a remedy in this case. View "Nelson v. Nelson" on Justia Law

Minn. Stat. 260C.301(1)(b)(4) provides that parents who previously have had their parental rights to children involuntarily terminated are presumed to be palpably unfit to parent other children. In this case, a few weeks after Hennepin County filed a petition to terminate Parents’ rights to their four children, Mother gave birth to a fifth child. The juvenile court terminated Parents’ rights to their four older children. The County subsequently filed a petition to terminate Parents’ rights to the newborn pursuant to section 260C.301(1)(b)(4). The juvenile court found that both parents failed to overcome the presumption of unfitness and that it was in the child’s best interests to terminate their parental rights. The court of appeals affirmed. Mother filed a petition for judicial review, arguing that the presumption of palpable unfitness found in section 260C.301(1)(b)(4) violates the Equal Protection Clause of the Minnesota and United States Constitutions. The Supreme Court affirmed, holding that section 260C.301(1)(b)(4) is narrowly tailored to serve the government’s compelling interest, and therefore, the statute does not violate the equal protection provisions of the State or Federal Constitutions. View "In re Welfare of the Child of R.D.L. & J.W." on Justia Law

After Gordon Brown’s debt to Citizens State Bank Norwood Young America (Bank) became delinquent, Gordon petitioned to dissolve his twenty-three-year marriage to Judy Brown. The Browns executed a marital termination agreement that was incorporated into the marital dissolution decree. Pursuant to the dissolution judgment and decree, Gordon transferred to Judy several assets. When it was unable to collect from Gordon on the original judgment, the Bank brought this action under Minnesota’s Uniform Fraudulent Transfer Act (MUFTA) to levy execution on the assets Gordon transferred to Judy, alleging that the transfers were made with the intent to defraud the Bank. The district court granted summary judgment in favor of the Bank, determining that the transfers were voidable under MUFTA. The court of appeals affirmed. The Supreme Court affirmed the district court’s judgment granting the Bank authority to levy execution on assets fraudulently transferred to the extent necessary to satisfy the Bank’s claim, holding that MUFTA applies to transfers made pursuant to an uncontested marital dissolution decree. View "Citizens State Bank Norwood Young Am. v. Brown" on Justia Law