Justia Minnesota Supreme Court Opinion Summaries

After parental rights to an Indian child were involuntarily terminated in district court, the White Earth Band of Ojibwe (the Band) petitioned for transfer of the ensuing preadoptive placement proceedings to its tribal court. The district court granted the Band's motion even though the child did not reside and was not domiciled within the tribe's reservation. The court of appeals affirmed. The Supreme Court reversed, holding that with respect to an Indian child not residing or domiciled on the child's tribe's reservation, (1) the Indian Child Welfare Act (ICWA) permits transfer to tribal court of only foster care placement and termination of parental rights proceedings; and (2) Rule 48 of the Minnesota Rules of Juvenile Protection Procedure, providing for transfer of the juvenile protection matter to an Indian child's tribe, is limited to foster care placement and termination of parental rights proceedings. View "In re R.S." on Justia Law

D.T.R., a minor, was born in 2004 to Lynette Marthe and her then-husband Derek Reiter. At the time, both believed Reiter was D.T.Râs biological father. However, in 2007, genetic testing would prove that Michael Richards was D.T.R.âs biological father. In 2008, Richards sought joint legal custody of D.T.R., and named Marthe and Reiter as parties. Before trial, the parties stipulated paternity, but could not agree who should be deemed D.T.R.âs âlegalâ father. The case proceeded to trial in 2009. While the paternity suit was pending, Marthe and Reiter had filed for divorce. In 2010, the district court filed detailed and thorough findings of fact and conclusions of law, and issued an order that concluded that a parent-child relationship existed between Reiter and D.T.R., and adjudicated Reiter as the childâs âlegalâ father. Marthe appealed the courtâs determination of paternity, but Richards did not. The appellate court questioned Martheâs standing to appeal the dismissal of Richardsâ petition. After additional briefing on the issue, the appellate court dismissed Martheâs appeal. On appeal to the Supreme Court, Marthe argued that she had standing to appeal as an aggrieved party pursuant to the applicable state case law and the Minnesota Parentage Act. Reiter asserted that Marthe did not have standing because her rights were not affected by the judgment adjudicating paternity. According to Reiter, Martheâs rights would be affected when her individual interests were at stake, such as a decision determining custody, parenting time or child support. The Supreme Court concluded that Marthe had standing to appeal as an aggrieved party the district courtâs determination of D.T.R.âs paternity. The Court reasoned that the determination of paternity directly impacted her responsibility for child support and her rights related to child support. The Court reversed the appellate courtâs holding, and remanded the case for further proceedings.

In 1988, Respondent Linda Dahlin obtained a judgment for unpaid spousal support against Appellant Randall Kroening. In 1998, the judgment was extended for an additional ten years pursuant to state law. In 2008, Respondent filed suit with the district court to renew the judgment for another ten years. The court denied the request holding that the judgment could only be renewed once. A divided appellate court reversed the district court, holding that the judgment could be renewed. The Supreme Court settled the split in the lower courts by holding that Respondent could renew her judgment, and that the state law did not limit action on a judgment to one renewal. The Court affirmed the appellate courtâs decision.