Cited by

Id.; (citing Minn. R. Evid.

“A district court abuses [its] discretion [regarding parenting time] by making findings unsupported by the evidence or improperly applying the law.” (d 705, 710 (Minn. 1985)).

We analyzed the 25% -19 (Minn. App. 2010).

“A district court abuses [its] discretion by making findings unsupported by the evidence or improperly applying the law.” Hagen v. Schirmers

See, (“The guiding principle in all custody cases is the best interest of the child.”); Hagen v. Schirmers , (“ The statute and caselaw make clear that the ultimate issue [when determining parenting time] is the child’s best interests [.]”); Schisel v. Schisel , d 265, 270 (Minn. App. 2009) (“The bedrock principle underlying any decision affecting the custody of minor children is that th

Hagen 12 v. Schirmers, (stating that “[b]ecause [an] aspect of the parenting-time issue was never argued to the district court o r sufficiently raised in [the party’s] principal brief to us, we consider the issue waived”).

We review the district court’s custody and parenting-time determinations for “whether the [district] court abused its discretion by making findings unsupported by the evidence or by improperly applying the law.”

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.”

5(a) (2014); (stating that ultimate concern in parenting-time dispute is child’s best interests).

(this court generally addresses only matters presented to and considered by the district court); (“[A] district court [should] 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).

5(a) (2014); (stating that child’s best interest is ultimate concern in parenting-time dispute).

“The statute and caselaw make clear that the ultimate issue is the child[ren]’s best interests as assessed under the totality of the considered factors.” (citing Minn. Stat. § 518.175, subd.

Todd relies on this court’s to argue that omitting consideration of the 25 percent presumption is an abuse of discretion.

But “electronic communication is not parenting time and does not count towards the 25% presumption.”

This court has held 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).

“A district court abuses [its] discretion by making findings unsupported by the evidence or improperly applying the law.”

We have said that the 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.” 15 (emphasis added).

Although subdivision 1(g) establishes a presumption, “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 8 parties.”

1(g) (2014).3 The statutory presumption can be rebutted by findings “related to the child’s best interests and considerations of what is feasible given the circumstances of the parties.”

This court has stated 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.”

“A district court abuses [its] discretion by making findings unsupported by the evidence or improperly applying the law.” ().