Cited by
Opinions in Minnesota that cite Nelson v. Nelson, 806 N.W.2d 870.
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In re the Estate of Stephen Singer, Deceased.
Minn. Ct. App. 2026
And appellate courts “will not disturb an appropriate order to clarify, implement, or enforce terms of a decree, absent an abuse of discretion.”
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In re the Marriage of: Laura Marie Knutsen v. Peder Nels Knutsen
Minn. Ct. App. 2026
(concluding that a district court may issue an order to enforce the provisions of a decree so long as it does not change any substantive rights).
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In Re the Marriage of:
Minn. Ct. App. 2026
The district court may issue an order to enforce its final dissolution decree “so long as it does not change the parties’ substantive rights.” (quotation omitted).
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In the Marriage of:
Minn. Ct. App. 2026
Much as a district court has discretion in enforcing a property settlement, and in deciding whether to reopen and modify a property settlement, a district court that retains jurisdiction over a property settlement has discretion in determining whether and how to modify it.
- In re the Marriage of: Todd Charles Bork v. Carolyn Mitsu Bork Minn. Ct. App. 2026
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In re the Marriage of: Todd Charles Bork v. Carolyn Mitsu Bork
Minn. Ct. App. 2026
DECISION This matter concerns the district court’s order enforcing the terms of the parties’ J&D. “This court will not disturb an appropriate order to clarify, implement, or enforce terms of a decree, absent an abuse of discretion.”
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In re the Marriage of:
Minn. Ct. App. 2025
This court has made it clear that “[ w]hile a district court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of the decree, so long as it does not change the parties’ substantive rights.”
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In Re the Marriage of:
Minn. Ct. App. 2025
But “[w]hile a district court may not modify a final property division, it may issue orders 5 to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (quotation omitted).
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In re the Marriage of:
Minn. Ct. App. 2025
“While a district court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (quotation omitted).
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A23-1981
Minn. Ct. App. 2025
Appellate courts “will not disturb an appropriate order to clarify, implement, or enforce terms of a decree, absent an abuse of discretion.” d 870, 871 (Minn. App. 2011).
- In re the Marriage of: Minn. Ct. App. 2024
- In re the Marriage of: Minn. Ct. App. 2024
- Michelle Lynn Wilson v. Ryan Converse Wilson Minn. Ct. App. 2024
- Michelle Lynn Wilson v. Ryan Converse Wilson Minn. Ct. App. 2024
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In re the Marriage of:
Minn. Ct. App. 2024
DECISION “While a district court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (quotation omitted).
- In re the Marriage of: 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
6 While “a district court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (quotation omitted).
- In re the Marriage of: Deborah Kay Schadewald, n/k/a Deborah Kay DeJong, petitioner, Respondent, Minn. Ct. App. 2024
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Khan Turouk, Appellant,
Minn. Ct. App. 2023
Finally, we addressed the merits of Turuok’s claim: [E]ven if his request for relief could be considered timely, Minnesota law is clear that “a [district] court may not modify a final property division” except to “implement, enforce, or clarify the provisions of the decree, so long as it does not change the parties’ substantive righ ts.” (quotation 4 omitted).
- In re the Marriage of: Amanda Leigh Davis Floyd, petitioner, Appellant, Minn. Ct. App. 2023
- In re the Matter of: Minn. Ct. App. 2023
- In re the Marriage of: Minn. Ct. App. 2023
- In re the Marriage of: Minn. 2022
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In re the Marriage of:
Minn. Ct. App. 2022
Second, although “a district court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (emphasis added) (quotation omitted); (recognizing that district court has discretion to use QDRO to implement division of pension rights).
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In re the Marriage of: Nyawan Kuon Dak, petitioner, Respondent,
Minn. Ct. App. 2022
Second, even if his request for relief coul d be considered timely, Minnesota law is clear that “a [district] court may not mo dify a final property division” except to “implement, enforce, or clarify the provisions of the decree, so long as it does not change 5 the parties’ substantive rights.” (quotation omitted).
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In re the Marriage of: David Paul Andresen, petitioner, Respondent,
Minn. Ct. App. 2022
Nelson v. Nelson , d 870, 871 (Minn. App. 2011).
- In re the Marriage of: Brad Allen Friesz, petitioner, Respondent, Minn. Ct. App. 2022
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In re the Marriage of: Linsey Lee Milbrandt, petitioner, Respondent,
Minn. Ct. App. 2021
We “treat stipulated marriage-dissolution judgments as contracts for purposes of construction.”
- In re the Marriage of: Jeffrey Scott Jovaag, petitioner, Appellant, Minn. Ct. App. 2021
- Kristina Marie Saenz, petitioner, Appellant, Minn. Ct. App. 2021
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In re the Marriage of: Jennifer Kristin Gorney, petitioner, Appellant,
Minn. Ct. App. 2021
For this argument, 4 4 We note that this is the only legal authority cited in either party’s brief.
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In re the Matter of: Brian Eugene Wolf, petitioner, Appellant,
Minn. Ct. App. 2021
(stating this principle as applied to stipulated dissolution judgment).
- In re the Marriage of: Kristine Ann Spratt Hansen, n/k/a Kristine Ann Spratt, petitioner, Respondent, Minn. Ct. App. 2020
- A19-1182 Minn. Ct. App. 2020
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In re the Marriage of: Susan Lee Wood, petitioner, Respondent,
Minn. Ct. App. 2019
Nelson v. Nelson , (M inn.
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In re the Marriage of: Christopher Warren Rupp, petitioner, Respondent,
Minn. Ct. App. 2019
A district court may issue orders to implement or enforce provisions of a judgment, , and appellate courts will not alter a district court’s implementation of a judgment provision unless the district court abuses its discretion
- In re the Marriage of: Tiffany Elizabeth Jean Banerjee, petitioner, Respondent, Minn. Ct. App. 2019
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In re the Marriage of: Laurie S. Morris Hiniker a/k/a Laurie Suzette Morris, petitioner, Respondent,
Minn. Ct. App. 2019
“Generally, a lien secures an underlying obligation.” see also Minn. Stat. § 514.99, subd.
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In re the Marriage of: Scott Douglas Wiggins, petitioner, Respondent,
Minn. Ct. App. 2018
But, a district court “may issue orders to implement, enforc e, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (quotation omitted).
- In re the Marriage of: Minn. Ct. App. 2018
- In re the Marriage of: Benjamin Robert Lewis, petitioner, Appellant, Minn. Ct. App. 2017
- Johnson v. Johnson 902 N.W.2d 79 Minn. Ct. App. 2017
- Johnson v. Johnson 902 N.W.2d 79 Minn. Ct. App. 2017
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In re the Marriage of: Dawn R. Imme, n/k/a Dawn RaNee Edwardson, petitioner, Appellant,
Minn. Ct. App. 2017
19, 2008); d 870, 872 (Minn. App. 2011) ( “Courts treat stipulated marriage -dissolution judgments as contracts for purposes of construction.” ).
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In re the Marriage of: Pamela J. Atkinson n/k/a Pamela J. Kraker, petitioner, Appellant,
Minn. Ct. App. 2017
“An order implementing or enforcing a dissolution decree does not affect the parties’ substantive rights when it does not increase or decrease the original division of marital property.”
- In re the Marriage of: Amy Christine Olmsted, f/k/a Amy Christine Zarbok v. William Scott Zarbok Minn. Ct. App. 2016
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In re the Marriage of: Amy Christine Olmsted, f/k/a Amy Christine Zarbok v. William Scott Zarbok
Minn. Ct. App. 2016
“‘While a [district] court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.’” (alteration in original) ().
- Carleen Kaye Theno, n/k/a Carleen Kaye Starkovich v. John Marvin Theno Minn. Ct. App. 2016
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Carleen Kaye Theno, n/k/a Carleen Kaye Starkovich v. John Marvin Theno
Minn. Ct. App. 2016
“While a district court may not modify a final property division,” such as the division of pension benefits in a judgment and decree, “it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” (quotation omitted).