Cited by

-41 (Minn. 2018) (stating that, in motion filed under section 518.175, subdivision 5(b), “best-interests-of-the-child standard requires consideration of factors such as” two of twelve factors in section 518.17, subdivision 1(a) (emphasis added)).

interests of the child” and if “the child’s present environment endangers the child’s physical or emotional health or impairs the child’s emotional 9 development and the harm likely to be caused by a change of environment is outweighed by the advantage of a change to the child.” Minn. Stat. § 518.18(d)(iv) (2024); -41 (Minn. 2018).

“[A] district court has broad discretion in determining custody and parenting time matters.”

based on endangerment must demonstrate that “(1) the circumstances of the [child] or custodian have changed; (2) modification would serve the [child’s] best interests; (3) the [child’s] present environment endangers their physical health, emotional health, or emotional development; and (4) the benefits of the change outweigh its detriments with respect to the [child].” see also Minn. Stat. § 518.18(d)(iv) (setting forth endangerment standard for custody modification).

4 (discussing non- exhaustive factors for determining whether a motion to modify parenting time is a de facto motion to modify physical custody).

-43 (Minn. 2018) (explaining that modification of parenting time can constitute modification of physical custody so as to require application of section 518.18(d)).

d on endangerment must establish that (1) “the circumstances of the child or custodian have changed ”; (2) “modification would serve the [child’s] best interests”; (3) “the [child’s] present environment endangers their physical health, emotional health, or emotional development ”; and (4) “the benefits of the change outweigh its detriments with respect to the [child].” see also Minn. Stat. § 518.18(d)(iv) (2024) (setting forth endangerment standard for custody modification).

see also Minn. Stat. § 518.18(d)(iv) (2024) (setting forth endangerment standard for custody modification).

6 District courts have “broad discretion in determining custody and parenting time matters.” ().

to endangerment must demonstrate that “(1) the circumstances of the children or custodian have changed; (2) modification would serve the children’s best interests; (3) the children’s present environment endangers their physical health, emotional health, or emotional development; and (4) the benefits of the change outweigh its detriments with respect to the children.”

on endangerment must demonstrate that “(1) the circumstances of the children or custodian have changed; (2) modification would serve the children’s best interests; (3) the children’s present environment endangers their physical health, emotional health, or emotional development; and (4) the benefits of the change outweigh its detriments with respect to the children.” Minn. Stat. § 518.18(d)(iv).

-42 (Minn. 2018) (establishing that a substantial parenting-time modification may be a de facto custody modification).

Minn. Stat. § 518.18(d)(iv)

n endangerment must demonstrate that “(1) the circumstances of the children or custodian have changed; (2) modification would serve the children’s best interests; (3) the children’s present environment endangers their physical health, emotional health, or emotional development; and (4) the benefits of the change outweigh its detriments with respect to the children.” Minn. Stat. § 518.18(d)-(e) (2022).

er a motion to modify parenting time is a de facto modification to physical custody, and therefore requires an application of the standard to modify custody rather than parenting time, “a court should consider the totality of the circumstances to determine whether the proposed modification is a substantial change that would modify the parties’ custody arrangement.” (emphasis added).

(determining whether Minn. Stat. § 518.175, subd.

Minn. Stat. § 518.18(d)(iv)

We are not persuaded toward a different understanding of residence by Seivers’s reliance on the supreme court’s

(noting that “a district court has broad discretion in determining custody and parenting time”) .

The supreme court has also directed that we are to look at the totality of the circumstances, 12 considering such factors as “the apportionment of parenting time, the child’s age, the child’s school schedule, and the distance between the parties’ homes, but these factors are not exhaustive.”

oving party must allege four elements: “(1) the circumstances of the children or custodian have changed; (2) modification would serve the children’s best interests; (3) the children’s present environment endangers their physical health, emotional health, or emotional development; and (4) the benefits of the change outweigh its detriments with respect to the children.” (quotation omitted).

dissolution-related judgment under Minn. Stat. § 518.145 (2020) in favor of preserving the discretion of the trial court); (refusing to “create a bright-line rule regarding how a district court exercises its discretion in evaluating the financial resources” on a motion to amend 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 t

Because motions to modify custody and motions to modify parenting time are subject to different standards, a district court may need to determine “whether a motion to modify parenting time is a de facto motion to modify physical custody for purposes of deciding whether the endangerment standard applies.”

parenting time.” (stating that third- party custody determinations are reviewed for an abuse of discretion).

(determining whether a proposed modification to parenting time is a substantial change that would effectively modify the parties’ custody arrangement requires the court to consider the totality of the circumstances, including among others, the apportionment of parenting time, the child’s age, th

(considering whether the best-interests standard of Minn. Stat. § 518.175, subd.

(refusing to create a “bright- line rule” for determining whether a request to change parenting time was actually a motion to modify custody, in part because a “m athematical rule” would “conflict[] with the governing principle that a district court ha s broad discretion in determining custody and

(not ing that “a district court has broad discretion in determining cu stody and parenting time”); see also Minn. Stat. § 518.003, subd.

(“the law makes no distinction between 2 Mother did not file a brief with this court; still, “the case shall be determined on the merits.” Minn. R. Civ.

7 A motion to modify parenting time constitutes a de facto motion to modify custody when, under “the totality of the circumstances,” “the proposed modification is a substantial change that would modify the pa rties’ custodial arrangement.”

Christensen v. Healey (In re Custody of MJH), -41 (Minn. 2018).

d 437, 443 (Minn. 2018) (noting that “a distri ct court has broad discretion in determining custody and parenting time”); (noting that “the law makes no distinction between general determinations of custody and resolution of specific issu es of custodial care”), revie

(Christensen I), rev’d on other grounds

d 437, 440 (Minn. 2018).