Cited by
Opinions in Minnesota that cite Maschoff v. Leiding, 696 N.W.2d 834.
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In re the Marriage of: Laura Marie Knutsen v. Peder Nels Knutsen
Minn. Ct. App. 2026
d 834, 840 (Minn. App. 2005) (noting importance of identifying baseline circumstances in stipulated dissolution judgments).
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In the Marriage of: Vydehi Aravalli v. Rajagopal Naga Aravalli
Minn. Ct. App. 2026
(“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
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In re the Matter of: David Terrance Kellogg v. Alyssa Leigh Freund
Minn. Ct. App. 2025
“[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).
- In the Matter of the Welfare of the Child of: B. L. and B. T., Parents., A25-0623, Court … Minn. Ct. App. 2025
- In the Matter of the Welfare of the Child of: B. L. and B. T., Parents., A25-0623, Court … Minn. Ct. App. 2025
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In re the matter of: Tiffany Dust f/k/a Tiffany Dust-Chlebik v. Beau Kevin Wayne f/k/a Kevin Chlebik
Minn. Ct. App. 2024
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 .
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In re the Custody of: O. J. M.-P
Minn. Ct. App. 2024
(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
- Leslie E. Sheehy Lee v. Travis W. Kalis, County of Le Sueur Minn. Ct. App. 2024
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Leslie E. Sheehy Lee v. Travis W. Kalis, County of Le Sueur
Minn. Ct. App. 2024
-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).
- 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
2(b)(1), means “their circumstances at the time of the motion to modify.”
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In re the Marriage of: Michael F. Kohorst v. Teressa L. Kohorst
Minn. Ct. App. 2022
“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).
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In re the Marriage of: Kevin Max Peterson v. Rebecca Jane Peterson, County of Dakota, Intervenor
Minn. Ct. App. 2021
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’”) (
- In re the Marriage of: Hirut Woldemariam v. Dereje F. Gulema Minn. Ct. App. 2021
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Trung Thien Do v. Kim Lang Thi Nguyen
Minn. Ct. App. 2021
“[T]he availability and application of res judicata and collateral estoppel in family law matters is limited .” Maschoff v. Leiding , .
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Deborah Lynn Nichols v. Scott Gerald Nichols
Minn. Ct. App. 2021
“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.”
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In the Matter of the Welfare of the Child of: M. J. K. and J. W. L., Parents
Minn. Ct. App. 2020
10 estoppel); Maschoff v. Leiding , (“[T] he availability and application of res judicata and collateral estoppel in family matters is limited .
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In re the Marriage of: Jane Swenson Amdal v. Keith Solomon Moheban
Minn. Ct. App. 2020
(examining child-support orders).
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In re the Marriage of: Jill Melisa Sinda v. Richard Joseph Sinda
Minn. Ct. App. 2020
See Maschoff v. Leiding , (noting importance of identifying baseline circumstances in stipulated dissolution judgments).
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In re the Marriage of: Paul Matthias Hobday v. Mary Kay Hobday
Minn. Ct. App. 2020
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).
- James Vernon Larsen, et al v. Heather Cross, et al Minn. Ct. App. 2019
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In re the Matter of: Dennis J. Arvig v. Trudy A. Kawlewski, County of Wadena, Intervenor
Minn. Ct. App. 2019
(“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
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In re the Matter of: Bradley Joseph Patraw, and Ramsey County, intervenor v. Alicia Kay Wittmer
Minn. Ct. App. 2019
(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).
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In re the Marriage of: Michelle E. Li-Kuehne v. Stephen E. Kuehne
Minn. Ct. App. 2018
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.
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In re the Marriage of: Nathan Gregory Olstad v. Stephanie Christine Olstad
Minn. Ct. App. 2018
(making this observation in the context of a child support dispute) .
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In re the Marriage of: Julie M. Steen v. Keven L. Steen
Minn. Ct. App. 2017
-41 (Minn. App. 2005) (directing courts to make findings of fact addressing the parties’ existing circumstances in child-support orders).
- In re the Marriage of: Beth Ostergaard Stillwell v. Harry Alan Stillwell Minn. Ct. App. 2016
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In re the Marriage of: Beth Ostergaard Stillwell v. Harry Alan Stillwell
Minn. Ct. App. 2016
“We review de novo whether res judicata precludes an issue from being relitigated.”
- Hennepin County, Mamie Jegbadai v. Gbenga Akinnola Minn. Ct. App. 2016
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Hennepin County, Mamie Jegbadai v. Gbenga Akinnola
Minn. Ct. App. 2016
(noting that, even in family-law matters, with the terms of a court order for repayment of past support .
- Hennepin County, Mamie Jegbadai v. Gbenga Akinnola Minn. Ct. App. 2015
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Hennepin County, Mamie Jegbadai v. Gbenga Akinnola
Minn. Ct. App. 2015
(noting that, even in family-law matters, “an adjudication on the merits of an issue is conclusive, and should not be relitigated” (quotation omitted)).
- In the Matter of the Welfare of the Children of: K. E. L. and J. L. W., Parents Minn. Ct. App. 2014
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In the Matter of the Welfare of the Children of: K. E. L. and J. L. W., Parents
Minn. Ct. App. 2014
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).
- State of Minnesota v. Mahdi Hassan Ali 855 N.W.2d 235 Minn. 2014
- Frank-Bretwisch v. Ryan 741 N.W.2d 910 Minn. Ct. App. 2007
- Frank-Bretwisch v. Ryan 741 N.W.2d 910 Minn. Ct. App. 2007