Cited by

ause of “the fact-dependent nature of the inquiry,” the supreme court has held that “a [district] court has broad discretion in deciding whether to award maintenance 12 and before an appellate court determines that there has been a clear abuse of that discretion, it must determine that there [is] a clearly erroneous conclusion that is against logic and the facts on record.” (quotation omitted).

The first step is a threshold inquiry into whether the party seeking spousal maintenance has made a “showing of need.” (quotation omitted).

First, a district court considers whether the spouse seeking spousal maintenance has made a “showing of need.” d 249, 252 (Minn. 2016).

8 Our supreme court has recognized that “a district court cannot require a maintenance-seeking spouse to invade the principal of the property awarded to a spouse seeking maintenance to pay living expenses.” (quotation omitted).

1 (2024 ).1 This threshold inquiry asks, in essence, whether the party seeking spousal maintenance has made a “showing of need.” (quotation omitted).

5b (titled “Modification”) (2024).5 Like Kostelnik, Schmidt also interpreted a different subdivision in the statute— the subdivision related to an obligee’s “showing of need.” d at 226 (); see also Minn. Stat. § 518.552, subd.

ause of “the fact -dependent nature of the inquiry, ” the supreme court has held that “a [district] court has broad discretion in deciding whether to award maintenance and before an appellate court determines that there has been a clear abuse of that discretion, it must determine that there [is] a clearly e rroneous conclusion that is against logic and the facts on record.” (quotation omitted).

DECISION An award of spousal maintenance “depends on a showing of need.” (quotation omitted).

(spousal maintenance); Lee v. Lee , (division of marital property); (attorney fees).

The district court “has broad discretion in deciding whether to award maintenance.” (d 249, 252 (Minn. 2016)).

See Torchwood Props., () (continuances); d 96, 100 (Minn. 2002) (division of marital property); (spousal maintenance).

24 324 n.8 (Minn. 2021).

This threshold inquiry asks, in essence, whether the party seeking spousal maintenance has made a “showing of need.”

A district court abuses its discretion if it reaches a “ conclusion that is against logic and the facts on record.” (quoting Dobrin, d at 202).

(“Given the fact- dependent nature of the inquiry, we have said that a trial court has broad discretion in deciding whether to award maintenance .

end or eliminate a spousal- maintenance award); (“[A] mathematical rule [that would automatically treat a request for equal parenting time as a request to modify physical custody would conflict] with the governing principle that a district court has broad discretion in determining custody and parenting time matters.”); -54 (Minn. 2016) (rejecting, in a spousal-maintenance dispute, a proposed “bright-line rule” because that proposed rule would, among other things, be “inconsistent with a district

The threshold inquiry is whether the spouse seeking maintenance has demonstrated a “showing of need.”

see also Honke, d at 269 (requiring district courts “to consider whether the prin cipal of post-dissolution cash gifts is a source 4 Regarding respondent’s argument that appella nt forfeited his challenge to the district court’s finding of bad faith by failing to address the district c

A district court abuses its discretion if it resolves the matter in a manner “that is against logic 5 and the facts on record.” ().

1 (2020) (stating circumstances under which sp ousal maintenance may be awarded); -52 (Minn. 2016).

edents cited by the parties dealt with either marital property awards; pre -dissolution, non-marital property; or the income of the payor spouse.” Honke then cites four cases: Broms v. Broms , (implicitly recognizing that a maintenance-seeking spouse could use the income from a pre -dissolution non -marital family trust for self -support); Curtis v. Curtis , -55 (Minn. 20 16) (considering the income potential of a stock portfolio awarded as part of a marital property award); Erlandson v. Erlands

Further: Given the fact-dependent nature of the inquiry, we have said that a “trial court has broad discretion in deciding whether to award maintenance and before an appellate court determines that there has been a clear abuse of that discretion, it must determine that there must be a clearly erroneous conclusion that is against logic and the facts on record.” ().

1(a )-(b) (2018); -52 (Minn. 2016).

First, the district court must consider whether the party seeking spousal maintenance has demonstrated a “showing of need.” Curtis v. Curtis

A district court abuses its discretion if it reaches a conclusion “that is against logic and the facts on record.” Curtis v. Curtis , (q uotation omitted).

A district court abuses its discretion if it resolves the matter in a manner “that is against logic and the facts on record.” (quotation omitted).

Curtis v. Curtis , d 249, 252 (Minn. 2016).