Cited by
Opinions in Minnesota that cite Nelson v. Nelson, 806 N.W.2d 870.
- In re the Marriage of: Julie Karen Johnson v. Thomas Francis Johnson, Jr. Minn. Ct. App. 2026
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Troy Andre Amundson v. Lora Daly Amundson
Minn. Ct. App. 2026
See Nelson v. Nelson , (reviewing an order implementing or enforcing a dissolution judgment for an abuse of discretion).
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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: Ikechukwu H. Aguocha v. Barbara Y. Agbo
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: Jeneen Marie Molldrem v. Kevin Daniel Molldrem
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: John A Laumann v. Kelly M Laumann
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: Yasser ElShaar v. Samia Bella
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: Mary Ellen Rice (FKA) Block v. William Ray Block
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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In re the Marriage of: Brent Lee Florine v. Lauren Marie Florine
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: Edward Luke Lazzaro v. Susan Louise Coen Minn. Ct. App. 2024
- In re the Marriage of: Lauren Elizabeth Schrock v. Richard Albert Kuhn 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: David Gordon Wingad v. Janet Marie Wingad
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: Cassandra Ann Petri v. John Edward Petri 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 v. Gregory John Schadewald Minn. Ct. App. 2024
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Khan Turouk v. Nyawan Kuon Dak, United States Department of Agriculture Rural Housing Services
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 v. Michael Scott Floyd Minn. Ct. App. 2023
- In re the Matter of: Elizabeth Joy Glirbas (n/k/a Elizabeth Joy Southwell) v. Joshua Robert Glirbas Minn. Ct. App. 2023
- In re the Marriage of: Gretchen Ann Plombon v. Brandon John Plombon Minn. Ct. App. 2023
- In re the Marriage of: Minn. 2022
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In re the Marriage of: Jacqueline Anne Johanning Probst v. Thomas Raymond Probst
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 v. Khan Deng Turuok
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 v. Leslie Ann Andresen
Minn. Ct. App. 2022
Nelson v. Nelson , d 870, 871 (Minn. App. 2011).
- In re the Marriage of: Brad Allen Friesz v. Elizabeth Farr Friesz Minn. Ct. App. 2022
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In re the Marriage of: Linsey Lee Milbrandt v. Jeffrey Robert Milbrandt
Minn. Ct. App. 2021
We “treat stipulated marriage-dissolution judgments as contracts for purposes of construction.”
- In re the Marriage of: Jeffrey Scott Jovaag v. Melissa Jo Helene Jovaag Minn. Ct. App. 2021
- Kristina Marie Saenz, Brown County Human Services v. Nicholas Lee Horman Minn. Ct. App. 2021
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In re the Marriage of: Jennifer Kristin Gorney v. Keith Joseph Gorney
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 v. Mandy Marie Oestreich
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 v. Christopher Patrick Hansen Minn. Ct. App. 2020
- In re the Marriage of: Beth Marie Delzer v. Randy Edward Delzer Minn. Ct. App. 2020
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In re the Marriage of: Susan Lee Wood v. Brad Wesley Wood
Minn. Ct. App. 2019
Nelson v. Nelson , (M inn.
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In re the Marriage of: Christopher Warren Rupp v. Elisabeth Hastings Felten, f/k/a Elisabeth Hastings Felten Rupp
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 v. Animesh Banerjee Minn. Ct. App. 2019
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In re the Marriage of: Laurie S. Morris Hiniker a/k/a Laurie Suzette Morris v. Robert Lee Hiniker
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 v. Marjarie Marie Renteria Wiggins
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: Vitamin v. Misha Gordin Minn. Ct. App. 2018
- In re the Marriage of: Benjamin Robert Lewis v. Elle Hawkinson Frane, f/k/a Michelle Marie Lewis 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 v. Michael B. Imme
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 v. Thomas E. Atkinson
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) ().