Cited by

d 834, 840 (Minn. App. 2005) (noting importance of identifying baseline circumstances in stipulated dissolution judgments).

(“Unless a support order provides a baseline for future modification motions by reciting the parties’ then-existing circumstances, the litigation of a later motion to modify that order becomes unnecessarily complicated because it requires the parties to litigate not only their circumstances

“[T]he availability and application of res judicata and collateral estoppel in family matters is limited, but the underlying principle that an adjudication on the merits of an issue is conclusive, and should not be relitigated, clearly applies.” Maschoff v. Leiding , (quotation omitted).

7 For this reason, we do not address father’s res judicata and collateral estoppel arguments except to note that “the availability and application of res judicata and collateral estoppel in family matters is limited.” Maschoff v. Leiding , see Loo v. Loo , , 743 -44, 744 n.1 (Minn .

(stating in the child-support context that “[u]nless a support order provides a baseline for future modification motions by reciting the parties’ then-existing circumstances, the litigation of a later motion to modify that order becomes unnecessarily complicated because it requires the parti

-41 (Minn. App. 2005) (remanding for further findings when district court’s order failed to address parties’ then-existing circumstances or provide baseline for deciding future modification motions).

2(b)(1), means “their circumstances at the time of the motion to modify.”

“Whether there is a substantial change in circumstances rendering an existing support obligation unreasonable and unfair generally requires comparing the parties’ circumstances at the time support was last set or modified to their circumstances at the time of the motion to modify.” () (applying standard to a decision to modify child support).

Tarutis v. Comm’r of Revenue, (observing that “the availability and application of res judicata and collateral estoppel in family matters is limited, but ‘the underlying principle that an adjudication on the merits of an issue is conclusive, and should not be relitigated, clearly applies’”) (

“[T]he availability and application of res judicata and collateral estoppel in family law matters is limited .” Maschoff v. Leiding , .

“Whether there is a substantial change in circumstances rendering an existing support obligation unreasonable and unfair generally requires comparing the parties’ circumstances at the time support was last set or modified to their circumstances at the time of the motion to modify.”

10 estoppel); Maschoff v. Leiding , (“[T] he availability and application of res judicata and collateral estoppel in family matters is limited .

(examining child-support orders).

See Maschoff v. Leiding , (noting importance of identifying baseline circumstances in stipulated dissolution judgments).

s pointed out by this court in Maschoff v. Leiding, unless a support order recites “the parties’ then-existing circumstances, the litigation of a later motion to modify that order becomes unnecessarily complicated because it requires the parties to litigate not only their circumstances at the time of the motion, but also their circumstan ces at the time of the order sought to be modified.” (citing Hecker, d at 709).

(“U nless a support order provides a baseline for future modification motions by reciting the parties’ then-existing circumstances, the 2 Arvig appears to contend that the case information sheet filed by Wadena County (the county), including the

(stating that determining whether a substantial change in circumstances renders an existing obligation unreasonable and unfair generally requires comparing the parties’ circumstances at the time support was last set or modified to their circumstances at the time of the motion to modify).

In the child -support context, this court has noted that d etermining whether a substantial change in circumstances has occurred requires “comparing the parties’ circumstances at the time support was last set or modified to their circumstances at the time of the motion to modify .” 3 Husband argues that Minnesota law presumes that a 20% change in an obligee’s gross income is considered a substantial change in circumstanc es.

(making this observation in the context of a child support dispute) .

-41 (Minn. App. 2005) (directing courts to make findings of fact addressing the parties’ existing circumstances in child-support orders).

“We review de novo whether res judicata precludes an issue from being relitigated.”

(noting that, even in family-law matters, with the terms of a court order for repayment of past support .

(noting that, even in family-law matters, “an adjudication on the merits of an issue is conclusive, and should not be relitigated” (quotation omitted)).

Bd., (stating in addition to the four-factor test that “a court applying collateral estoppel must be convinced that its application is fair”); (holding that res judicata and collateral estoppel have limited application to family law matters).