Cited by

(stating that particularized findings promote the use of statutory standards, explain the district court’s decision to parties, and facilitate meaningful appellate review).

(holding that, when the district court has broad discretion, “it is especially important that the basis for the court’s decision be set forth with a high degree of particularity if appellate review is to be meaningful”).

The purpose of particularized findings in child-custody matters is to “(1) assure consideration of the statutory factors by the family court; (2) facilitate appellate review of the family court’s custody decision; and (3) satisfy the parties that this important decision was carefull y and fairly considered by the family court.”

The district court must explain both its decision and why it made its decision to “(1) assure consideration of the statutory factors by the family court; (2) facilitate appellate review of the family court’s custody decision; and (3) satisfy the parties that this important decision was carefully and fairly considered by the family court.”

-70 (Minn. App. 2020) (citing this aspect of Rosenfeld in a juvenile-protection appeal); (concluding that district court’s findings of fact were deficient when the findings were “i

See, (stating, in a custody dispute, that findings on the statutory factors are required because they “(1) assure consideration of the statutory factors by the family court; (2) facilitate appellate review of the family court’s custody decision; and (3) satisfy the parties that this important decision

d 168, 171 (Minn. 1976).

(noting, in the context of an initial custody award, that findings of fact should show that the district court considered the relevant factors, allow appellate review of its decision, and assure the parties that the district court fairly reached its decision)

12, 1993); (noting, on appeal of a custody award, that findings of fact explaining a district court’s exercise of its discretion are necessary to “(1) assure consideration of the statutory factors by the [district] court; (2) facilitate appellate review of the [district] court’s custody decision; and (3) sa

The district court must make findings to “permit 5 reasoned appellate review” and to ensure that “the relevant statutory factors have been addressed.” ().

201; see also Honke v. Honke , 10 Preliminarily, we observe that other caselaw establishes that “the district court is not required to make specific findings on every statutory factor if the findings that were made reflect that the district court adequately considered the relevant statutory factors.” (); (holding “that the district court was required to consider only the relevant best-interest factors in [the parenting-time modification statute], and was not required to make specific and detaile

(citing this aspect of Rosenfeld).

See Rosenfeld v. Rosenfeld , (noting, on appeal of a custody award, that findings of fact explaining a district court’ s exercise of its discretion are necessary to “(1) assure consideration of the statutory factors by the [district] court; (2) facilitate appellate review of the [district] court’s custody decision; and (3) sa

See Rosenfeld v. Rosenfeld , (noting, on appeal of a custody award, that findings of fact explaining a district court’s exercise of its discretion are necessary to “(1) assure consideration of the statutory factors by the [district] court; (2) facilitate appellate review of the [district] court’s custody decision; and (3) sa

5 Two cases guide our analysis: Rosenfeld v. Rosenfeld , , 170 -72 (Minn. 1976) and In re Civil Commitment of Spicer

d 538, 547 (Minn. App. 2009); 14 (noting that a child’s best interests are “generally not susceptible to an appellate court’s global review of a record” ); (noting, on appeal of a custody award, that findings of fact explaining a district court’s exercise of its discretion are necessary to “(1) assure consideration of the statutory factors by the [district] court; (2) facilitate appellate review of the [district] court’s custody decision; and (3) s

(stating that findings of fact addressing the relevant criteria “(1) assure consideration of the statutory factors by the family court; (2) facilitate appellate review of the family court’s [decision on the question at issue]; (3) satisfy the parties that this important decision was carefully and

decision; and (3) satisfy the parties that this important decision was carefully and fairly considered by the [district] court.” (child- custody case); see also In re Civil Commitment of Ince , (citing Rosenfeld and noting that, while “[t]he evidence in the record may be sufficient t o support [the district court’s] conclusion, .

See Rosenfeld v. Rosenfeld , -72 (Minn. 1976) (holding tha t findings explaining a distric t court’s exercise of its discretion are necessary to assure that the relevant factors have been addressed, to provide appellate courts with an adequate basis to review the exercise of that discretion, and to assure the parties that the relev ant f

See, (stating, in a custody dispute, that findings on the statutory factors are required because 16 they “(1) assure consideration of the statutory f actors by the family court; (2) facilitate appellate review of the family court’s custody decision; and (3) satisfy the parties that this important dec

Minn. Stat. § 260C.511(a) (2016).

See Rosenfeld v. Rosenfeld , 311 Minn. 76, 82, 249 N.W.

See, e.g., Rosenfeld v. Rosenfeld, 311 Minn. 76, 82, (stating, in a custody dispute , that findings on the statutory factors are required because they “(1) assure consideration of the statutory factors by the family court; (2) facilitate appellate review of the family court’s custody decision; and (3) satisfy the parties that this im

Rosenfeld 9 v. Rosenfeld, 311 Minn. 76, 82

Rosenfeld v. Rosenfeld, 311 Minn. 76, 82

ion, that findings of fact explaining a district court’s exercise of its discretion are necessary to “(1) assure consideration of the statutory factors by the [district] court; (2) facilitate appellate review of the [district] court’s custody decision; and (3) satisfy the parties that this important decision was carefully and fairly considered by the [district] court.” Rosenfeld v. Rosenfeld, 311 Minn. 76, 82

See Rosenfeld v. Rosenfeld, 311 Minn. 76, 81-82, Wallin v. Wallin, 290 Minn. 261, 266-67, -66 (Minn. App. 1993), review denied (Minn. Jan.

Rosenfeld v. Rosenfeld, 311 Minn. 76, 82

For example, in Rosenfeld v. Rosenfeld, 311 Minn. 76, a case concerning child custody, the supreme court held that a district court “must make written findings which properly reflect its consideration” of the relevant statutory factors.

P. 52.01 (stating that in actions tried upon facts without a jury, “the court shall find the facts specially and state separately its conclusions of law”); Rosenfeld v. Rosenfeld, 311 Minn. 76, 82 , (stating that findings of fact will “assure consideration of the statutory factors ...

Rosenfeld v. Rosenfeld, 311 Minn. 76, 82

(citing Rosenfeld v. Rosenfeld, 311 Minn. 76, 83 , -72 (1976)).

Rosenfeld v. Rosenfeld, 311 Minn. 76, 83

Rosenfeld v. Rosenfeld, 311 Minn. 76, 82 , (appellate court mandate for findings enhances respect for standards, informs the parties of the court’s rationale, and gives the parties a meaningful right to appeal).