Cited by

3 (requiring reply brief to be “confined to new matter raised in the brief of the respondent”); (declining to consider appellant’s argument that district court’s order amounted to restriction in parenting time 8 because it was never raised to the district court and raised for the first time in appellant’s reply brief.).

“The law leaves scant if any room for an appellate court to question the district court’s balancing of best-interests considerations.” (quotation omitted).

Appellate courts “defer[] to and [do] not reassess the district court’s credibility determinations.”

Minimum Parenting-Time Presumption On appeal, this court considers “whether [a] district court abused its discretion by not following the statutory 25% parenting -time presumption.” Hagen v. Schirmers

at *4; see also Hagen v. Schirmers , (recognizing district court’s broad discretion in family matters and stating that effective appellate review is not possible unless the district court explains both its decision and the reasons for that decision).

Parenting-time awards below the 25-percent threshold “can be justified by reasons related to the child’s best interests and considerations of what is feasible given the circumstances of the parties.”

Our caselaw provides that a district court must “demonstrate an awareness and application of the 25% presumption when the issue is appropriately raised and the court awards less than 25% parenting time.” (emphasis added).

Although the record includes information about the parties’ financial resources, the record “is nevertheless inadequate if that record fails to reveal that the [district] court actually considered the appropriate factors.” -18 (Minn. App. 2010) (noting that appellate courts have instructed district courts to “identify both [their] decision (e.g., spousal maintenance, child support, parenting time) as well as the underlying reason(s) for that decision (i.e., findings showing why the amount of mai

-19 (Minn. App. 2010) (reversing a parenting-time determination for failure to consider a statutory 25% parenting-time presumption and remanding for the district court to consider the presumption when the district court was aware of the presumption but did not address it and ordered that a parent would receive

This court has stated that district courts must “demonstrate an awareness and application of the 25% presumption when the issue is appropriately raised and the court awards less than 25% parenting time.” (emphasis added).

RDNT, -76 (Minn. 2015); (noting on review of district court’s discretionary, custody-related decision that “district court must identify both its decision .

d 212, 217 (Minn. App. 2010).

“[A] ‘restriction’ requires a finding of endangerment or noncompliance with court orders.” see also Minn. Stat. § 518.175, subd.

The district court must “demonstrate an awareness and application of the 25% presumption when the issue 13 is appropriately raised and the court awards less than 25% parenting time.”

broad discretion over family law issues, the appellate courts have instructed the district courts to “ide ntify both [their] decision (e.g., spousal maintenance, child support, parenting time) as well as the underlying reason(s) for that decision (i.e., findings showing why the amount of maintenance, child support or parenting time is appropriate in the particular case).” - 18 (Minn. App. 2012) ( ).

RDNT, -76 (Minn. 2015); -18 (Minn. App. 2010) (noting on review of district court’s discretionary, custody- related decision that “the district court must identify both its decision .

parenting-time allocations that merely fall below the 25% presumption can be justified by reasons related to the child’s best interests and considerations of what is feasible given the circumstances of the parties.”

-18 (Minn. App. 2010) (citing cases).

RDNT, d 71, 75-76 (Minn. 2015) ; see Hagen v. Schirmers , -18 (Minn. App. 2010) (noting, in the context of reviewing a district court’s discretionary, custody -related 13 decision, that “the district court must identify both its decision .

only required when a district court imposes a restriction: “Although a ‘restriction’ requires a finding of endangerment or noncompliance with court orders, parenting -time allocations that merely fall below the 25% presumption can be justified by reasons related to the child ’s best interests and considerations of what is feasible given the circumstances of the parties.” (citation and footnote omitted).

1(b) (2018); (noting that “a ‘restriction’ requires a finding of endangerment or noncompliance with court orders”).

10 is feasible given the circumstances of the parties.” (citation omitted).

Hagen v. Schirmers , d 212, 215 (Minn. App. 2010).

(noting that court must “demonstrate an awareness and application of the 25% presumption when the issue is appropriately raised and the court awards less than 25% parenting time”).

Hagen v. Schirmers , (noting that district courts are required “ to demonstrate an awareness and application of the 25% presumption when the issue is appropriately raised and the court awards less tha n 25% parenting time ”) (emphasis added).

See Thiele v. Stich , (stating that appellate court s consider only those issues presented to and considered by the district court); (requiring “district court[] to demonstrate an awareness and application of the 25% presumption when the issue is appropriately raised and the court awards less than 25% parenting time” (emphasis added)).

District courts must “demonstrate an awareness and application of the 25% presumption when the issue is appropriately raised and the court awards less than 25% parenting time.” (emphasis added).

“The statute and caselaw make clear that the ultimate issue is the child’s best interests as assessed under the totality of the considered factors .” Hagen v. Schirmers , (emphasis added).