Cited by

1(a) (2022), even though it was not required to do so in addressing a motion for parenting-time modification, Hansen v. Todnem

But, because we are remanding for further proceedings, we take this opportunity to emphasize that a district court “must make sufficient findings to enable appellate review.” n.2 (Minn. 2018); see Rosenfeld v. Rosenfeld, 2 (noting, on appeal of a custody award, that findings of fact explaining a district court’s exercise of its discretion are necessary to “(1) assure consideration of the statutory factors by the [district] court; (2) facilitate appel

The Minnesota Supreme Court’s supports our interpretation of the statute.

Hansen v. Todnem , aff’d on other grounds

Hansen v. Todnem , aff’d on other grounds

See Thiele v. Stich, 10 “District courts have broad discretion on matters of custody and parenting time.”

Hansen v. Todnem , (district courts exercise “broad discretion” when deciding custody matters).

Hansen v. Todnem , Minn. Stat. § 518.175 (2022).

“District courts have broad discretion on matters of custody and parenting time.”

See Minn. Stat. § 260.012(h); - 98 (Minn. 2018) (holding that district court must consider best- interest factors in section 518.175, subdivision 8, but need not make findings on each factor).

(stating that a district court abuses its discretion if it misapplies the law, makes findings unsupported by the record, or resolves discretionary questions in a manner that is contrary to logic and the facts on record).

On appeal, we review a district court’s findings of fact on the best-interests factors for clear error, and the court’s balancing of those factors for an abuse of discretion

The district court’s factual findings “regarding the best-interest factors are reviewed for clear error.”

We acknowledge that “[d]istrict courts have broad discretion on matters of custody and parenting time.”

The district court’s factual findings “regarding the best-interest factors are reviewed for clear error.”

is unsupported by the text of the parenting-time statutes.”

(eliminating the previously recognized common-law distinction between 10 substantial and insubstantial modifications of parenting time and requiring court to make adequate findings).

Hansen v. Todnem , , aff’d on other grounds

other caselaw establishes that “the district court is not required to make specific findings on every statutory factor if the findings that were made reflect that the district court adequately considered the relevant statutory factors.” (); (holding “that the district court was required to consider only the relevant best-interest factors in [the parenting-time modification statute], and was not required to make specific and detailed findings on those factors” when not required by statute).

See, (citing Goldman v. Greenwood , ).

d 592, 599 (Minn. 2018) (concluding, in the context of a request for additional parenting time under section 518.175, subdivision 8, that “parenting time modifications .

on and even forfeited parenting time to evade process[,]” “failed to follow the Court’s directives as to communications with [appellant,]” and “took every opportunity to interfere with the parenting time exchanges” ; it also noted that “the record is replete with [respondent’s] hostile text messages and obstreperous conduct.” 14 App. 1984) , overruled on other grounds by Hansen v. Todnem

See 20 -64 (Minn. App. 2017), aff’d on other grounds

See Hansen v. Todnem , (concluding that Minn. Stat .