Cited by
Opinions in Minnesota that cite Rosenfeld v. Rosenfeld, 249 N.W.2d 168.
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In Re the Custody of BJS: Joseph Stanton v. Amber Lee Finley, County of Fillmore
Minn. Ct. App. 2026
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.”
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In re the Marriage of: Rachel Naomi Simpson v. Jonathan Edward Simpson
Minn. Ct. App. 2026
(stating that particularized findings promote the use of statutory standards, explain the district court’s decision to parties, and facilitate meaningful appellate review).
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In re the Marriage of: David Ray Honeman v. Carol Lynn Honeman
Minn. Ct. App. 2026
(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”).
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In re the Marriage of: Matthew Alan Rivera v. Miranda Rae Rivera
Minn. Ct. App. 2026
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.”
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In re the Custody of: O. J. M.-P
Minn. Ct. App. 2024
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.”
- In re the Marriage of: Hillary Mercer Graves v. Richard Charles Graves Minn. Ct. App. 2024
- In the Matter of the Welfare of the Children of: A. S., D. S., C. P., J. H., … Minn. Ct. App. 2024
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In the Matter of the Welfare of the Children of: A. S., D. S., C. P., J. H., …
Minn. Ct. App. 2024
-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
- In re the Marriage of: Emily Lynn Rasmussen v. Nicholas Steven Rasmussen Minn. Ct. App. 2024
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In re the Marriage of: Emily Lynn Rasmussen v. Nicholas Steven Rasmussen
Minn. Ct. App. 2024
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
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In re the Marriage of: Amy Joy Kemp v. Michael Edward Kemp
Minn. Ct. App. 2023
d 168, 171 (Minn. 1976).
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In Re the Custody of: X. W. F., Anthony Dexter Wayne Francis v. Denise Tonche
Minn. Ct. App. 2023
(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)
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In the Matter of the Welfare of the Child of: A. M. L., Commissioner of Human Services, Legal …
Minn. Ct. App. 2022
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
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In re the Marriage of: Donald Wayne Leeke v. Susan Lynn Webb Leeke, n/k/a Susan Lynn Leeke
Minn. Ct. App. 2022
The district court must make findings to “permit 5 reasoned appellate review” and to ensure that “the relevant statutory factors have been addressed.” ().
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In re the Marriage of: John Alex Walker v. Laura Margaret Walker
Minn. Ct. App. 2021
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
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In re the Marriage of: Katherine Theresa Blair v. Campbell Johnston Blair
Minn. Ct. App. 2021
(citing this aspect of Rosenfeld).
- In the Matter of the Welfare of the Children of: K. E. S., M. W. C., and T. … Minn. Ct. App. 2021
- Nicole A. Nyhus, Hennepin County v. Sokkhan Ka Minn. Ct. App. 2020
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In re the Custody of: N. Y. B., James Edward Bono v. Megan Yvonne Hedberg
Minn. Ct. App. 2020
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
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Michael Anthony Guardia v. Jennifer Marie Mattson
Minn. Ct. App. 2020
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
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Joan Elizabeth Toll v. Commissioner of Public Safety
Minn. Ct. App. 2020
5 Two cases guide our analysis: Rosenfeld v. Rosenfeld , , 170 -72 (Minn. 1976) and In re Civil Commitment of Spicer
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In the Matter of the Welfare of the Child of J. R. R., Parent
Minn. Ct. App. 2020
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
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In re the Marriage of: Jesse A. Freking v. Audra Jo Buxengard f/k/a Audra Jo Freking
Minn. Ct. App. 2018
(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
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In re the Guardianship and Conservatorship of: Reinhold Struhs
Minn. Ct. App. 2018
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, .
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In the Matter of the Welfare of the Child of: Q. S. M. and T. R. S., Parents
Minn. Ct. App. 2018
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
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In re the Marriage of: Bijoy Raghavan v. Smeeta Antony
Minn. Ct. App. 2018
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
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In the Matter of the Welfare of the Children of: M. D. J., L. W., and R. L., …
Minn. Ct. App. 2018
Minn. Stat. § 260C.511(a) (2016).
- In the Matter of the Welfare of the Child of: J. A. T. and R. N. V., Parents Minn. Ct. App. 2018
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In re the Guardianship of Daniel J. Carlson
Minn. Ct. App. 2018
See Rosenfeld v. Rosenfeld , 311 Minn. 76, 82, 249 N.W.
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In re the Matter of: Peter H. Stier v. Debra A. Peterson, n/k/a Debra A. Hershberger, County of …
Minn. Ct. App. 2017
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
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Renee Wiskow, et al v. Zachary O’Reilly
Minn. Ct. App. 2017
Rosenfeld 9 v. Rosenfeld, 311 Minn. 76, 82
- Christensen v. Healey 899 N.W.2d 573 Minn. Ct. App. 2017
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Christensen v. Healey
899 N.W.2d 573
Minn. Ct. App. 2017
Rosenfeld v. Rosenfeld, 311 Minn. 76, 82
- In the Matter of the Welfare of the Children of: M. A. K. and A. L. P., Sr., … Minn. Ct. App. 2016
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In the Matter of the Welfare of the Children of: M. A. K. and A. L. P., Sr., …
Minn. Ct. App. 2016
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
- Melissa Dawn Paisley v. Clark Davis Kratzer Minn. Ct. App. 2016
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Melissa Dawn Paisley v. Clark Davis Kratzer
Minn. Ct. App. 2016
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.
- In re the Marriage of: Anne Elizabeth Castle-Heaney v. Bruce Edward Heaney Minn. Ct. App. 2014
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In re the Marriage of: Anne Elizabeth Castle-Heaney v. Bruce Edward Heaney
Minn. Ct. App. 2014
Rosenfeld v. Rosenfeld, 311 Minn. 76, 82
- In the Matter of the Civil Commitment of: Gary George Spicer 853 N.W.2d 803 Minn. Ct. App. 2014
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In the Matter of the Civil Commitment of: Gary George Spicer
853 N.W.2d 803
Minn. Ct. App. 2014
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.
- In re the Civil Commitment of Ince 847 N.W.2d 13 Minn. 2014
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In re the Civil Commitment of Ince
847 N.W.2d 13
Minn. 2014
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 ...
- Marriage of Hesse v. Hesse 778 N.W.2d 98 Minn. Ct. App. 2009
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Marriage of Hesse v. Hesse
778 N.W.2d 98
Minn. Ct. App. 2009
Rosenfeld v. Rosenfeld, 311 Minn. 76, 82
- Dailey v. Chermak 709 N.W.2d 626 Minn. Ct. App. 2006
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Dailey v. Chermak
709 N.W.2d 626
Minn. Ct. App. 2006
(citing Rosenfeld v. Rosenfeld, 311 Minn. 76, 83 , -72 (1976)).
- Marriage of Peterka v. Peterka 675 N.W.2d 353 Minn. Ct. App. 2004
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Marriage of Peterka v. Peterka
675 N.W.2d 353
Minn. Ct. App. 2004
Rosenfeld v. Rosenfeld, 311 Minn. 76, 83
- Marriage of Schubel v. Schubel 584 N.W.2d 434 Minn. Ct. App. 1998