Cited by
Opinions in Minnesota that cite Marriage of Erlandson v. Erlandson, 318 N.W.2d 36.
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In re the Marriage of: Marianne Michele Thayer v. Larry Frank Thayer
Minn. Ct. App. 2026
ation determinations [when] the district court failed to tie potential income to present, concrete job opportunities” and that “the trial court erred by improperly analyzing the spousal maintenance factors.” “A district court generally has broad discretion in its decisions regarding spousal maintenance.” ().
- In re the Marriage of: Laura Marie Knutsen v. Peder Nels Knutsen Minn. Ct. App. 2026
- In re the Marriage of: Michael Raymond Baer v. Kelley Michelle Baer Minn. Ct. App. 2026
- In the Marriage of: Vydehi Aravalli v. Rajagopal Naga Aravalli Minn. Ct. App. 2026
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In the Marriage of: Todd Charles Sherette v. Melissa Ann Sherette
Minn. Ct. App. 2026
2; -40 (Minn. 1982) (discussing the statutory factors).
- In re the Marriage of Zachary Dean Hollingsworth v. Anne Marie Halling Roe Minn. Ct. App. 2025
- In re the Marriage of Zachary Dean Hollingsworth v. Anne Marie Halling Roe Minn. Ct. App. 2025
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In re the Marriage of: Mishaun Ahmad v. Nancy J. Christensen
Minn. Ct. App. 2025
2 (2024); -40 (Minn. 1982).
- In re the Marriage of: Amanda Marie-Gladys Johnson v. Joseph Lyle Johnson Minn. Ct. App. 2025
- In re the Marriage of: Ryan Russell Preusse v. Amanda Jayne Preusse Minn. Ct. App. 2025
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In re the Marriage of: Ryan Russell Preusse v. Amanda Jayne Preusse
Minn. Ct. App. 2025
A. When determining whether to award spousal maintenance, the district court’s overall focus is on “the financial needs of [the spouse seeking maintenance] and [their] ability to meet those needs balanced against the financial condition [of the spouse from whom maintenance is sought].” -40 (Minn. 1982).
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In re the Marriage of: Craig Jerald Mackey v. Beth Ann Mackey
Minn. Ct. App. 2024
(“A trial court’s determination of the amount and duration of spousal maintenance is final unless the court abused the discretion accorded to it.” ()); (“The standard of review for an appellate court examining an award of attorney fees is whether the district 2 Because we reverse the district court’s decision regarding its classification of the 5.78- acre property as nonmarital, we do not reach
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In re the Marriage of: Tabitha Ann Sanborn v. Matthew Charles Sanborn
Minn. Ct. App. 2023
“[N]o single statutory factor for determining the type or amount of ma intenance is dispositive” and “each case must be determined on its own facts.” .
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In re the Marriage of: Angela Marie Backman v. Charles Robert Backman
Minn. Ct. App. 2023
2; se e -40 (Minn. 1982).
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In re the Marriage of: Richard Leo Bassing v. Barbara Laraine Bassing
Minn. Ct. App. 2022
d 36, 40 (Minn. 1982) (affirming 54% -46% property division); (affirming 53%-47% property division); (affirming 57.5%-42.5% property division where the district court considered that, “were it not for appell
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In re the Marriage of: Kimberly Erin Macfarlane v. Bruce Travis Adam Macfarlane
Minn. Ct. App. 2022
While the spousal maintenance statute does not specify whether the district court must consider gross income versus net income, “it usually is necessary for the district court to consider a spouse’s obligation to pay income taxes when determining his or her ability to provide adequate self-support through employment.” Id.; (affirming a maintenance award noting that the recipient’s “[reasonable] monthly expenses exceeded her net take- home salary”) (emphasis added ); Schmidt, d at 229 (reversing
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In re the Marriage of: Kelly Susan LaPara v. Timothy Michael LaPara
Minn. Ct. App. 2022
The statute provides a non- exclusive list of eight relevant factors, but the overarching focus is on “the financial needs of [the spouse seeking maintenance] and her ability to meet those needs balanced against the financial condition of [the spouse from whom maintenance is sought].” -40 (Minn. 1982).
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In re the Marriage of: Melissa F. Feierabend v. David Feierabend, and State of Minnesota, County of St. …
Minn. Ct. App. 2021
four cases: Broms v. Broms , (implicitly recognizing that a maintenance-seeking spouse could use the income from a pre -dissolution non -marital family trust for self -support); Curtis v. Curtis , -55 (Minn. 20 16) (considering the income potential of a stock portfolio awarded as part of a marital property award); Erlandson v. Erlandson , (considering the investment income from a non-marital, pre-dissolution personal injury award as a source of income); (calculating the income of the payor spous
- In re the Marriage of: David Gordon Wingad v. Janet Marie Wingad Minn. Ct. App. 2021
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In re the Marriage of: Amy Lynn Callister (A20-1249) (A20-1261) v. Kevin Callister (A20-1249) (A20-1261)
Minn. Ct. App. 2021
The statute includes a non- exhaustive list of relevant factors, but the central inquiry is “basically the financial needs of [the party seeking maintenance] and [the party’s] ability to meet those needs balanced against the financial condition of [the spouse].” -40 (Minn. 1982).
- In re the Marriage of: John Alex Walker v. Laura Margaret Walker Minn. Ct. App. 2021
- In re the Marriage of: Martin Sean Schmidt v. Julie Ann Schmidt Minn. Ct. App. 2021
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Charles Edward Honke v. Jennifer Hodapp Honke
Minn. 2021
These awards are “based on the notion that the marital relationship involves an economic partnership in which the spouses equally share the burdens and responsibilities of both marriage and dissolution.”
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In re the Marriage of: Rupam Sinha v. Deepak Kademani
Minn. Ct. App. 2021
The weighing of the factors essen tially requires the district court to conduct “a balancing of the recipient’s need ag ainst the obligor’s ability to pay.” (-40 (Minn. 1982)).
- In re the Marriage of: Amy Jo Yurek, n/k/a Amy Jo Sellers v. Michael Francis Yurek Minn. Ct. App. 2021
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Deborah Lynn Nichols v. Scott Gerald Nichols
Minn. Ct. App. 2021
Although the district court must consider several statutory factors when setting or modifying spousal maintenance, “the issue is basically the financial needs of [the obligee] and her ability to meet those needs balanced against the financial condition of [t he obligor].” -40 (Minn. 1982).
- In re the Marriage of: Kimberly JoAnn Wauzynski, n/k/a/ Kimberly JoAnn Denne v. John Justin Wauzynski Minn. Ct. App. 2020
- In re the Marriage of: Ronald Lee Henrichs v. Charlene Lila Henrichs Minn. Ct. App. 2020
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In re the Marriage of: Edith Ponciano v. Felix Murillo
Minn. Ct. App. 2020
Although the statute lists several factors, the issue is “basically the financial needs of [the spousal-maintenance obl igee] and her ability to meet t hose needs balanced against the 4 financial condition of [the s pousal-maintenance obligor.]” Erlandson v. Erlandson , -40 (Minn. 1982).
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In re the Marriage of: Charles Robert Aufenthie v. Heidi Christine Aufenthie
Minn. Ct. App. 2020
Although the statute lists several factors, “the issue is basically the financial needs of [the maintenance oblige e] and her ability to meet those needs balanced against the financial condition of [the maintenance obligor].” -40 (Minn. 1982).
- In re the Marriage of: David Michael Kedrowski v. Olga Kedrowski Minn. Ct. App. 2019
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In re the Marriage of: Sheila L. Duhn, n/k/a Graff v. Kurt D. Duhn
Minn. Ct. App. 2019
2 (2018); -40 (Minn. 1982).
- In re the Marriage of: Nicole Marie Anne Sanders v. Joseph James Sanders Minn. Ct. App. 2019
- Madden v. Madden 923 N.W.2d 688 Minn. Ct. App. 2019
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Madden v. Madden
923 N.W.2d 688
Minn. Ct. App. 2019
2 ; see also Erlandson v. Erlandson , , 39-40 (Minn. 1982).
- In re the Marriage of: Laurie S. Morris Hiniker a/k/a Laurie Suzette Morris v. Robert Lee Hiniker Minn. Ct. App. 2019
- In re the Marriage of: Bijoy Raghavan v. Smeeta Antony Minn. Ct. App. 2018
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In re the Marriage of: Grace Kathryn Adams v. Frank Thomas Adams
Minn. Ct. App. 2018
2 ; see also Erlandson v. Erlandson , -40 (Minn. 1982) .
- In re the Marriage of: Lynn J. Dreger v. Richard C. Dreger Minn. Ct. App. 2018
- In re the Marriage of: Robert Joseph Hoolihan v. Jacqueline Ann Hoolihan Minn. Ct. App. 2018
- In re the Marriage of: Terry Anne Boggs v. David Carl Boggs Minn. Ct. App. 2018
- In re the Marriage of: Sandra Kay Vogt v. Gary Dennis Vogt Minn. Ct. App. 2018
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In re the Marriage of: Praveen Prabhakaran v. Vadivazhaghi Kannan
Minn. Ct. App. 2018
See Erlandson v. Erlandson , -40 (Minn. 1982).
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In re the Marriage of: Andrew Scott Green v. Julie Ann Green
Minn. Ct. App. 2017
In essence, the district court balances “the recipient’s needs against the obligor’s ability to pay.” (-40 (Minn. 1982)).
- In re the Marriage of: Jennifer Kristin Gorney v. Keith Joseph Gorney Minn. Ct. App. 2017
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In re the Marriage of: Teresa Marie Nordahl v. Steven Edward Nordahl
Minn. Ct. App. 2017
” Prahl v. Prahl, 627 (- 40 (Minn. 1982)).
- In re the Marriage of: Elena Vladimirovna Tokarev v. Vladimir Efimovich Tokarev Minn. Ct. App. 2017
- In re the Marriage of: Elena Vladimirovna Tokarev v. Vladimir Efimovich Tokarev Minn. Ct. App. 2017
- In re the Marriage of: Paul Grant Gardner v. Margaret Rose Gardner Minn. Ct. App. 2016
- In re the Marriage of: Paul Grant Gardner v. Margaret Rose Gardner Minn. Ct. App. 2016