Cited by
Opinions in Minnesota that cite Hagen v. Schirmers, 783 N.W.2d 212.
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Cody J Walker v. Leah Ann Defoe
Minn. Ct. App. 2026
Parenting-time allocations below the presumptive 25% “can be justified by reasons related to the child’s best interests and considerations of what is feasible given the circumstances of the parties.” d 212, 218 (Minn. App. 2010).
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In the Marriage of: Robert Raymond Jackson (A26-0033) v. Kadi Beth Jackson (A25-1612)
Minn. Ct. App. 2026
A district court “must identify both its decision” and “the underlying reason(s) for that decision.”
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In Re the Custody of L.B.O.; Bibi Whited, et al v. Kenzie Quinn, Tyler Ohman, Rachel Norgaard, et …
Minn. Ct. App. 2026
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.).
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In the Marriage of: Michaela Dojcinovic Bachmayer v. Kyle Dalke Bachmayer
Minn. Ct. App. 2026
“The law leaves scant if any room for an appellate court to question the district court’s balancing of best-interests considerations.” (quotation omitted).
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In re the Marriage of: Michael Raymond Baer v. Kelley Michelle Baer
Minn. Ct. App. 2026
Appellate courts “defer[] to and [do] not reassess the district court’s credibility determinations.”
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County of Hennepin v. Jill Kline Rochford, Ross Edgar Trooien
Minn. Ct. App. 2026
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
- In the Marriage of: Sarah Nicole Smith v. Jonathan George Smith Minn. Ct. App. 2026
- In the Marriage of: Sarah Nicole Smith v. Jonathan George Smith Minn. Ct. App. 2026
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In the Matter of: Bijal Mukesh Mehta v. Abheer Nabdakumar Jayakar
Minn. Ct. App. 2026
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).
- In re the Custody of the Children of: Nicole Marie Petersen v. Ruby Nivelo, Rafael Silva Minn. Ct. App. 2026
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In Re the Marriage of: Douglas Paul Sundberg v. Morgan Alexandria Sundberg
Minn. Ct. App. 2025
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.”
- In the Matter of: Cristina Lillian Mactaggart v. Jeffrey Allen Westad Minn. Ct. App. 2025
- In the Marriage of: Phourywathana Cardinale v. David Cardinale, Scott County, Intervenor Minn. Ct. App. 2025
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In the Marriage of: Varvara Viktorovna Tishchenko v. Joseph Monroe Cmiel, Ramsey County, Intervenor
Minn. Ct. App. 2025
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).
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James David Colburn v. Eunjin Jinny Colburn
Minn. Ct. App. 2025
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
- In re the Marriage of: Michelle Marie Dillavou v. Joseph Alex Abel Sirois Minn. Ct. App. 2024
- State of Minnesota v. Rashard Dujuan Ross Minn. Ct. App. 2024
- County of Hennepin v. Christina Elizabeth VonderHaar, James Mark Hedquist Minn. Ct. App. 2024
- County of Hennepin v. Christina Elizabeth VonderHaar, James Mark Hedquist Minn. Ct. App. 2024
- In re the Marriage of: Jessica Suzanne Cross v. Joseph Drew Cross Minn. Ct. App. 2024
- In re the Marriage of: David Gordon Wingad v. Janet Marie Wingad Minn. Ct. App. 2024
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In re the Marriage of: David Gordon Wingad v. Janet Marie Wingad
Minn. Ct. App. 2024
-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
- In re the Marriage of: Asma Javed v. Rizwan Siwani Minn. Ct. App. 2024
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In re the Marriage of: Asma Javed v. Rizwan Siwani
Minn. Ct. App. 2024
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).
- In the Matter of the Welfare of the Children of: D. L. W., Commissioner of Human Services, Legal … Minn. Ct. App. 2024
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In the Matter of the Welfare of the Children of: D. L. W., Commissioner of Human Services, Legal …
Minn. Ct. App. 2024
RDNT, -76 (Minn. 2015); (noting on review of district court’s discretionary, custody-related decision that “district court must identify both its decision .
- In the Matter of: Ester Berestov, on behalf of minor children v. Betsalel Berestov Minn. Ct. App. 2024
- In the Matter of: Ester Berestov, on behalf of minor children v. Betsalel Berestov Minn. Ct. App. 2024
- In re the Marriage of: Anita Karen Dunne, n/k/a Anita Karen Fischer v. Anthony Kieran Dunne Minn. Ct. App. 2024
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In the Matter of the Welfare of the Child of: M. A. B., Legal Custodian
Minn. Ct. App. 2024
d 212, 217 (Minn. App. 2010).
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In re the Marriage of: Philip Lynn Knutson v. Alissa Ann Knutson, Polk County Human Services, Intervenor
Minn. Ct. App. 2023
“[A] ‘restriction’ requires a finding of endangerment or noncompliance with court orders.” see also Minn. Stat. § 518.175, subd.
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In re the Marriage of: Amy Joy Kemp v. Michael Edward Kemp
Minn. Ct. App. 2023
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.”
- In re the Marriage of: Aane Serge-Rinehardt Fosse v. Denise Anne Fosse Minn. Ct. App. 2023
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County of Anoka, Aphton Marie Hansen v. David Matthew Shallman
Minn. Ct. App. 2022
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) ( ).
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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
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 .
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In re the Marriage of: Ellen Jo Schneider v. Jeffrey Daniel Schneider
Minn. Ct. App. 2022
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.”
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In the Matter of the Civil Commitment of: Anthony John Dentz
Minn. Ct. App. 2022
-18 (Minn. App. 2010) (citing cases).
- In re the Marriage of: Michelle Lynn Wilson, Ryan Converse Wilson, Co-Appellant v. Gayle Gaumer Minn. Ct. App. 2021
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In the Matter of the Welfare of the Child of: R. R. B., Commissioner of Human Services, Legal …
Minn. Ct. App. 2021
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 .
- In re the Marriage of: Christopher John Nieber v. Rebekah Kali Nieber, n/k/a Beka Kali Minn. Ct. App. 2021
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In re the Matter of: Brooks J. Waldron v. Uneica Nicole Garrett
Minn. Ct. App. 2021
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).
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Richard Minder III v. Jai Maria Negri
Minn. Ct. App. 2021
1(b) (2018); (noting that “a ‘restriction’ requires a finding of endangerment or noncompliance with court orders”).
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In re the matter of: Eric Thurman Clinton v. Gabriela Kathleen Linder
Minn. Ct. App. 2020
10 is feasible given the circumstances of the parties.” (citation omitted).
- Michael Anthony Guardia v. Jennifer Marie Mattson Minn. Ct. App. 2020
- In re the Custody of: R. T. R., C. T. R., and S. C. T. R., Robby Romero … Minn. Ct. App. 2020
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In re the Marriage of: Jacqueline Alice Jones v. Robert Ernest Jones
Minn. Ct. App. 2019
Hagen v. Schirmers , d 212, 215 (Minn. App. 2010).
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In re the Matter of: Awal Ismael Hussein v. Lensa Mohamed Musa
Minn. Ct. App. 2019
(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”).
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In re the Marriage of: John Richard Strosahl v. Doreen Strosahl
Minn. Ct. App. 2019
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).
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In re the Marriage of: Kristy Ann Ryan v. Jeffrey Alan Ryan
Minn. Ct. App. 2019
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)).
- In re the Marriage of: Terrence Michael Zelenka v. Annie Valeria Anderson, f/k/a Anne Zelenka Minn. Ct. App. 2019