In re the Marriage of: Abdihafid Hariri Hassan Yusuf, petitioner, Appellant,

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-1979

In re the Marriage of:
Abdihafid Hariri Hassan Yusuf, petitioner,
Appellant,

vs.

Neama Omar Y Al Somali,
Respondent.

Filed July 27, 2026
Affirmed
Reilly, Judge*

Ramsey County District Court
File No. 62-FA-22-1249

Abdihafid Hariri Hassan Yusuf, Roseville, Minnesota (pro se appellant)

Maria E. Maier, St. Paul & Ramsey County Domestic Abuse Intervention Project, St. Paul,
Minnesota (for respondent)

Considered and decided by Reyes, Presiding Judge; Bratvold, Judge; and Reilly,
Judge.
NONPRECEDENTIAL OPINION
REILLY, Judge
In this pro se appeal, appellant -father appeals from two district court orders
determining that father was a frivolous litigant and denying his motions to modify

* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
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parenting time, modify child support, award him a tax dependent exemption, and order
certain safety-related provisions regarding the parties’ joint child. We affirm.
FACTS
Appellant-father, Abdihafid Hariri Hassan Yusuf, and respondent- mother, Neama
Omar Y Al Somali, were married in October 2019. The parties have one joint child who
was born in 2020.
The parties separated in June 2021, and both filed petitions for an Order for
Protection (OFP) for themselves and on behalf of the child against the other party. Father
petitioned for a dissolution of the marriage in June 2022. The parties have a history of
extensive litigation in this dissolution matter and the related OFP matters.
In June 2021, father’s request for an ex parte OFP was denied and mother’s request
for an ex parte OFP was granted. In January 2022, after consolidated evidentiary hearings
on both OFP petitions, father’s petition was dismissed because the district court found that
his allegations were not proved. And an OFP was issued for mother against father with
findings that father committed acts of domestic abuse against mother. That order granted
mother temporary sole legal and physical custody of the child.
In orders from February, March, and June 2022, the district court denied father’s
repeated motions to modify custody in the OFP matter, determining that father had no basis
to modify custody and was instead attempting to relitigate the OFP. In orders from April
and June 2022, the district court denied father’s motion to modify child support in the OFP
matter, finding that father was voluntarily underemployed. Father then filed another
motion to modify the OFP seeking the same relief. Father also moved to disqualify the
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referee. And father filed a motion to modify the OFP seeking a modification of parenting
time and child support. Mother moved the district court for an order deeming father a
frivolous litigant in the OFP matter. The district court granted mother’s motion and
deemed father a frivolous litigant in the OFP matter, requiring him to either furnish a bond
of $5,000 or be represented by an attorney before filing any further motions in that matter.
Father did not file any more motions to modify the OFP.
In April 2024, after a two-day trial in this dissolution matter, the district court
entered a dissolution decree granting mother sole legal and sole physical custody of the
child, granting father supervised parenting time at FamilyWise, and ordering father to pay
child support. 1 As is also relevant to this appeal, the district court ordered that father
complete specific requirements to receive unsupervised parenting time, including requiring
that father attend nine consecutive months of consistent supervised parenting time at
FamilyWise. The district court found that father was voluntarily underemployed and
imputed to him a gross monthly income of $2,783. And the district court awarded mother
the right to claim the tax dependency exemption for the parties’ child because father had
less than ten percent of the overall parenting time.
In May 2024 father appealed the district court’s dissolution decree. We affirmed
the district court’s dissolution decree on appeal. Yusuf v. Al Somali, No. A24-0880, 2025
WL 826285, at *1 (Minn. App. Mar. 17, 2025).

1 FamilyWise is a parenting center which offers a variety of supervised parenting services.
4
Following this court’s opinion affirming the decree, father filed the motions at issue
in this appeal. In May 2025, father filed a motion and affidavit seeking to decrease basic
child support and child care support. The next day, father filed a motion and affidavit
requesting a modification to child support, physical custody, and parenting time, alleging
that mother committed acts of domestic abuse against him in June 2021, that mother abused
the child, and that mother’s brother was a threat to the child.
In June 2025, father filed an ex parte motion for emergency relief alleging that
mother’s brother posed an immediate threat to the child. In that motion, father also sought
an order preventing the child from being removed to Saudi Arabia by mother, a stay of his
driver’s license suspension, and an order vacating the dissolution decree based on a due-
process violation. The district court denied the motion. One week after the denial of the
first ex parte motion, father filed a second ex parte motion seeking the same emergency
relief. The district court denied that motion. The day following the denial of the second
ex parte motion, father moved to disqualify the referee.
In July 2025, mother moved to deem father a frivolous litigant in this matter. In
August 2025, father filed an amended motion and affidavit seeking to decrease child
support, alleging that his gross monthly income was $1,200 and that he was enrolled in a
master’s program, which he claimed was a bona fide career change. Mother filed a
responsive motion and affidavit, and father filed what looked like a reply brief in which he
repeated his same arguments about custody, child support, parenting time, and child
endangerment. In that filing, father also responded to mother’s claim that he was a
frivolous litigant.
5
Several days later in August 2025, father retained counsel. In September 2025,
represented by counsel, father filed an amended motion and affidavit conceding that he had
no basis to modify child custody and clarifying the relief he sought. Father requested
modifications to parenting time and to child support, an award of the tax dependency
exemption on an alternating annual basis, and an order prohibiting mother from allowing
the child to be alone with her brother and prohibiting the child from traveling to Saudi
Arabia.
Later that month, the district court held a motion hearing on mother’s frivolous-
litigant motion and father’s various requests in the amended motion. At the motion
hearing, father’s counsel clarified that father was withdrawing his request to disqualify the
referee and that the only relief father was seeking was what was stated in the amended
motion and affidavit filed by counsel.
In October 2025, the district court granted mother’s motion to deem father a
frivolous litigant in this dissolution matter and ordered that father either furnish a bond of
$5,000 or be represented by an attorney to file any further motions. And in November
2025, the district court denied father’s amended motion seeking a modification of parenting
time and child support, as well as an award of the tax dependency exemption and an order
prohibiting mother from allowing the child to be alone with her brother and prohibiting the
child from travelling to Saudi Arabia.
Father appeals these orders.

6
DECISION
Father seeks reversal of the district court’s order determining that he was a frivolous
litigant, and the district court’s order denying his amended motion.
Father is a self-represented litigant. “Although some accommodations may be made
for [self-represented] litigants, this court has repeatedly emphasized that [self-represented]
litigants are generally held to the same standards as attorneys and must comply with court
rules.” Fitzgerald v. Fitzgerald, 629 N.W.2d 115, 119 (Minn. App. 2001). Self-
represented litigants, like those represented by counsel, must support their claims with
“either arguments or citations to legal authority.” State v. Bartylla , 755 N.W.2d 8, 22
(Minn. 2008). An assignment of error in a brief based on “mere assertion” and not
supported by argument or authority is waived “unless prejudicial error is obvious on mere
inspection.” Schoepke v. Alexander Smith & Sons Carpet Co., 187 N.W.2d 133, 135
(Minn. 1971); see also Fannie Mae v. Heather Apartments Ltd. P’ship, 811 N.W.2d 596,
600 n.2 (Minn. 2012) (“Summary arguments made without citation to legal support are
waived.”). Nor do we presume error on appeal, and “the burden of showing error rests
upon the one who relies upon it.” Midway Ctr. Assocs. v. Midway Ctr., Inc., 237 N.W.2d
76, 78 (Minn. 1975). And we may decline to address inadequately briefed issues. See
State, Dep’t of Lab. & Indus. v. Wintz Parcel Drivers, Inc., 558 N.W.2d 480, 480 (Minn.
1997) (declining to address an inadequately briefed question).
With these principles in mind, we consider the many arguments raised by father on
appeal. He argues that the district court erred by: (1) concluding that he was a frivolous
litigant; (2) denying his request for a modification of parenting time; (3) denying his
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request for a modification of child support; (4) denying his request for an order prohibiting
mother from allowing the child to be alone with her brother; (5) denying his request for a
tax dependency exemption; and (6) relying on factually inaccurate statements and
translation errors and therefore violating father’s due-process rights. In addition, father
argues in his reply brief that (7) his due-process rights were violated because he never
received notice of mother’s frivolous-litigant motion. Father’s arguments and analysis are
largely unsupported by citations to legal authority and include many citations to cases that
we are unable to locate. Thus, many of father’s arguments are not properly before us. And
for the reasons explained below, we conclude that father’s arguments—regardless of
whether they are properly before us—do not support reversal of the district court’s orders.
I. The district court did not abuse its discretion by determining that father was a
frivolous litigant.

Father first challenges the district court’s frivolous-litigant determination.
We review a district court’s determination that a party is a frivolous litigant for an
abuse of discretion. See Szarzynski v. Szarzynski, 732 N.W.2d 285, 290, 294- 95
(Minn. App. 2007) (noting that the district court’s failure to apply the proper frivolous-
litigant standard found in Minnesota Rule of General Practice 9.01 was an abuse of
discretion). “A district court abuses its discretion by making findings of fact that are
unsupported by the evidence, misapplying the law, or delivering a decision that is against
logic and the facts on record.” Woolsey v. Woolsey, 975 N.W.2d 502, 506 (Minn. 2022)
(quotation omitted).

8
There are three definitions of “frivolous litigant” under Minn. Gen. R. Prac. 9.06(b):
(1) A person who, after a claim has been finally determined
against the person, repeatedly relitigates or attempts to
relitigate either

i. the validity of the determination against the same
party or parties as to whom the claim was finally
determined, or

ii. the cause of action, claim, controversy, or any of the
issues of fact or law determined or concluded by the
final determination against the same party or parties as
to whom the claim was finally determined; or

(2) A person who in any action or proceeding repeatedly serves
or files frivolous motions, pleadings, letters, or other
documents, conducts unnecessary discovery, or engages in oral
or written tactics that are frivolous or intended to cause delay;
or

(3) A person who institutes and maintains a claim that is not
well grounded in fact and not warranted by existing law or a
good faith argument for the extension, modification or reversal
of existing law or that is interposed for any improper purpose,
such as to harass or cause unnecessary delay or needless
increase in the cost of litigating the claim.

After notice and hearing on a motion to have a person declared a frivolous litigant, a district
court may, if it determines the person to be a frivolous litigant, require the frivolous litigant
to post security or impose preconditions that the frivolous litigant must meet to serve or
file any new claims, motions, or requests. Minn. Gen. R. Prac. 9.01. The district court
must consider seven factors in making its determination. Minn. Gen. R. Prac. 9.02(b)
In determining that father was a frivolous litigant, the district court considered each
of the seven factors and provided detailed reasoning. The district court explained that
(1) father repeatedly filed “motion after motion asking to modify custody, child support,
9
and other matters,” all of which had been denied; (2) there was no reasonable probability
father would prevail on pending motions; (3) father’s motions were a bad-faith attempt to
relitigate issues already decided, and he had already been deemed a frivolous litigant in the
related OFP matter involving mother for the same conduct; (4) mother had incurred costs
responding to father’s motions and had missed work for hearings on those motions; (5) the
prior sanctions deeming father a frivolous litigant in the related OFP matter effectively
stopped father from filing frivolous motions in that matter; (6) requiring father to be
represented by an attorney would defend against future frivolous motions; and (7) “[ n]o
less severe sanction [would] sufficiently protect the rights of the other litigants, the public,
or the courts.”
Father contends that the district court abused its discretion by deeming him a
frivolous litigant. Father argues that the district court failed to adequately consider the
availability of lesser sanctions, and that it “conflate[d] the number and lack of success of
his filings with a lack of good-faith basis.” He asserts that, instead, “[a] review of the
record demonstrates each cluster of motions was grounded in fact, warranted by law, and
filed for a proper purpose.”
But here, father does not dispute the district court’s factual findings, which the
record supports. Instead, father essentially asks us to reweigh the evidence on appeal,
which this court cannot do. See Sefkow v. Sefkow, 427 N.W.2d 203, 210 (Minn. 1988).
Moreover, father’s argument that the district court failed to consider the availability of
lesser sanctions is contradicted by the district court’s order. The district court specifically
noted that denying his prior motions had been insufficient to stop father from attempting
10
to relitigate the issues addressed in those motions. And the district court found that “[n]o
less severe sanction [would] sufficiently protect the rights of the other litigants, the public,
or the courts.” Father’s arguments therefore fail to persuade us that the district court abused
its discretion by deeming father a frivolous litigant under Minn. Gen. R. Prac. 9.06(b).
Father also argues that the imposition of the $5,000 bond violates his constitutional
right to due process and his fundamental parental rights. Specifically, he asserts that his
due-process rights are violated because the bond is disproportionate and essentially
punishes him for having a low income. And he asserts that his fundamental parental rights
are violated because he cannot file emergency motions related to the child’s safety, health,
or welfare.
But father failed to raise these arguments at any time before the district court. Father
therefore may not assert these arguments on appeal. See Thiele v. Stich, 425 N.W.2d 580,
582 (Minn. 1988) (stating that appellate courts generally address only those questions
previously presented to and considered by the district court).
In sum, based on our review, we are satisfied that the district court considered the
seven factors under Minn. Gen. R. Prac. 9.02(b) and adequately explained its reasoning
based on evidence in the record. And father fails to persuade us that the district court
otherwise abused its discretion by determining that he was frivolous litigant under Minn.
Gen. R. Prac. 9.06(b). See Midway Ctr. Assocs., 237 N.W.2d at 78.
We therefore conclude that the district court did not abuse its discretion in its
frivolous-litigant determination.
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II. The district court did not abuse its discretion by denying father’s request to
modify parenting time.

Father next challenges the district court’s denial of his request to modify parenting
time.
We review a decision about the modification of parenting time for an abuse of
discretion. Suleski v. Rupe, 855 N.W.2d 330, 334 (Minn. App. 2014). “A district court
abuses its discretion by making findings of fact that are unsupported by the evidence,
misapplying the law, or delivering a decision that is against logic and the facts on record.”
Woolsey, 975 N.W.2d at 506 (quotation omitted).
“District courts have broad discretion on matters of custody and parenting time.”
Hansen v. Todnem, 908 N.W.2d 592, 596 (Minn. 2018). But a district court’s parenting-
time determination must be guided by the best interests of the child.
Minn. Stat. § 518.17, subd. 1(a) (2024); Clark v. Clark, 346 N.W.2d 383, 385 (Minn. App.
1984) (“It is well established that the ultimate question in all disputes over [parenting time]
is what is in the best interest s of the child”), rev. denied (Minn. June 12, 1984).
Accordingly, a district court “shall” modify parenting time only if “modification would
serve the best interests of the child.” Minn. Stat. § 518.175, subd. 5(b) (2024). In
considering a request to modify parenting time, the district court need only consider the
relevant best-interests factors in section 518.17, subdivision 1, and it is
“not required to
make specific and detailed findings on those factors when considering [the movant’s]
modification request.” Hansen, 908 N.W.2d at 599. We will reverse a parenting-time
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determination for an abuse of discretion only if the district court made clearly erroneous
factual findings or improperly applied the law. See id. at 599.
In seeking a modification of parenting time, father argued that supervised parenting
time at FamilyWise was prohibitively expensive because he was only earning $1,200 a
month and was in school to earn a master’s degree in accounting and hoping to become a
certified public accountant (CPA). He therefore argued that his economic circumstance s
should not prohibit him from seeing his child. Father also argued that he completed many
of the district court’s requirements to receive unsupervised visitation with the child.
On this issue, the district court noted, and the record supports, that father conceded
that he had failed to exercise supervised parenting time as ordered. The district court
explained that father was asking for unsupervised parenting time but had not fulfilled the
requirements in its initial decree that would permit father to be granted unsupervised
parenting time—that father complete “nine consecutive months of consistent supervised
parenting time at FamilyWise.” The district court also reasoned that father’s argument that
he could not afford to participate in FamilyWise was not “convincing given that he is
currently underemployed.” And the district court also explained that father’s request to
have his brother supervise parenting time was not in the child’s best interests because
father’s brother was not neutral and “would not be able to ensure that Father would not say
negative things to the child about Mother.” The district court therefore denied father’s
request to modify parenting time.
On appeal, father contends that the district court abused its discretion by denying
his request to modify parenting time. Father argues that the district court failed to conduct
13
a new best-interests analysis, that the “financial impossibility” of the supervised visits was
a proper basis for modification, that the district court failed to consider his brother as a
reasonable alternative to FamilyWise, and that the district court improperly relied on
father’s past conduct without considering the steps he had taken to address its concerns.
We address each of father’s arguments in turn.
New Best-Interests Analysis
Father first asserts that the district court abused its discretion by failing to conduct
a new best-interests analysis.
But in considering a motion to modify parenting time, the district court only has to
consider the relevant best-interests factors and is not required to make specific findings on
each factor. See Hansen, 908 N.W.2d at 599. Although the district court here did not
identify any specific best-interest factors in denying father’s request to modify parenting
time, the court explained that the requested modification was not in the best interests of the
child. The district court also explained that father failed to abide by the terms of the initial
decree in which the district court determined that supervised parenting time was in the best
interests of the child. The district court’s reasoning therefore implies that it considered
relevant factors and was guided by the best interests of the child. See
Minn. Stat. § 518.17, subd. 1(a).
We therefore discern no abuse of discretion in the district court’s best-interests
analysis.

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Financial Impossibility
Father next argues that the “financial impossibility” of the supervised visits was a
proper basis for modification.
Father generally relies on Minn. Stat. § 518.175, subd. 5, asserting that “financial
impossibility” is a substantial change in circumstances that makes the current parenting-
time order “unreasonable and unfair.” He also asserts that, because of the order, he has not
seen his child in 18 months, which is contrary to public policy favoring “frequent and
continuing contact,” citing to Minn. Stat. § 518.17. And father argues that the district
court’s order is “premised on a critical, unstated assumption: that Father could afford the
ordered supervision.” He asserts that the “record is unequivocal that he cannot” and that
his monthly income is around $1,200.
Although father generally argued in district court that his financial circumstances
prevented him from engaging with supervised parenting time, father did not argue as he
does now that Minn Stat. §§ 518.17 and 518.175 authorize a modification of parenting time
based on a substantial change in financial circumstances rendering the existing parenting
time award unreasonable and unfair. Thus, the district court also did not consider or decide
whether Minn. Stat. §§ 518.17 or 518.175 authorize a modification of parenting time based
on financial circumstances.
2 As a result, this court may not consider arguments not raised

2 The analysis for modifying parenting time proposed by father —that a modification of
parenting time is based on a substantial change in circumstances rendering an existing
award unreasonable and unfair—is not in the parenting-time statutes. See
Minn. Stat. §§ 518.17; .175 (2024). Father’s proposed analysis, however, is similar to the
analysis district courts use to address whether to modify spousal maintenance and child
support. See Minn. Stat. § 518.552, subd. 5b (2024) (maintenance); Minn. Stat. § 518A.39
15
and considered in the district court. See Thiele, 425 N.W.2d at 582. To the extent that
father is challenging the district court’s finding that his claim that he could not afford
supervised parenting was “not convincing,” we defer to the district court’s credibility
determinations and do not reweigh evidence on appeal. See Sefkow, 427 N.W.2d at 210;
In re Civ. Commitment of Kenney, 963 N.W.2d 214, 221 (Minn. 2021).
For these reasons, father failed to show that the district court abused its discretion
by denying his request to modify parenting time based on his alleged financial
circumstances.
Remaining Arguments
As to father’s remaining claims—that the district court failed to consider his brother
as a reasonable alternative, and that the district court improperly relied on father’s past
conduct without considering the steps he has taken to address its concerns related to that
conduct—his arguments are unsupported by any citation to legal authority.
While father purports to cite caselaw to support his remaining arguments, the cases
cited do not exist and we are otherwise unable to locate those cases. Absent any other
citation to legitimate legal authority, father’s remaining claims that the district court abused
its discretion by denying his request to modify parenting time are not properly before us,
and we decline to address them. See Ganguli v. Univ. of Minn., 512 N.W.2d 918, 919 n.1
(Minn. App. 1994) (declining to address allegations unsupported by legal analysis or

(2024) (child support). Our analysis above assumes father’s proposed analysis for
modifying parenting time is viable, but we do not address the accuracy of that assumption
here.
16
citation); Melina v. Chaplin, 327 N.W.2d 19, 20 (Minn. 1982) (stating that inadequately
briefed issues are not properly before the court).
In sum, we discern no abuse of discretion in the district court’s parenting-time
determination. And father has failed to carry his burden to show that the district court
otherwise erred by denying his request to modify parenting time. See Midway Ctr. Assocs.,
237 N.W.2d at 78.
We therefore conclude that the district court did not abuse its discretion in denying
father’s request to modify parenting time.
III. The district court did not abuse its discretion by denying father’s motion to
modify child support.

Father next challenges the district court’s denial of his request to modify child
support.
The district court may modify a child-support order if there has been a substantial
change in circumstances that renders the terms of the order unreasonable and unfair.
Minn. Stat. § 518A.39, subd. 2(a). Two such bases that permit modification are a
substantial change in the obligor’s or obligee’s gross income and a substantial change in
child care expenses. Id. subd. 2(a)(1), (7); see also Minn. Stat. § 518A.40, subd. 4(c)
(2024) (permitting a modification of child care support under section 518A.39 when there
is a substantial increase or decrease in child care expenses). The moving party bears the
burden of proving both that there has been a substantial change in circumstances and that
the change makes the existing order unreasonable and unfair. Hecker v. Hecker , 568
N.W.2d 705, 709 (Minn. 1997).
17
We review orders modifying child support for an abuse of discretion.
Haefele v. Haefele, 837 N.W.2d 703, 708 (Minn. 2013). “A district court abuses its
discretion by making findings of fact that are unsupported by the evidence, misapplying
the law, or delivering a decision that is against logic and the facts on record.” Woolsey ,
975 N.W.2d at 506 (quotation omitted).
As is also relevant here, a parent moving for a modification of child support may
not rely on decreased income resulting from voluntary underemployment to show a
substantial change in circumstances that renders the original award unreasonable and
unfair. Ulrich v. Ulrich, 400 N.W.2d 213, 217 (Minn. App. 1987). But a parent is not
voluntarily underemployed upon a showing that the “underemployment, or employment
on a less than full-time basis is temporary and will ultimately lead to an increase in
income,” or “represents a bona fide career change that outweighs the adverse effect of that
parent’s diminished income on the child.” Minn. Stat. § 518A.32, subd. 3(1), (2) (2024).
It is the movant’s burden to show that the statutory requirements have been satisfied.
Putz v. Putz, 645 N.W.2d 343, 349 (Minn. 2002).
Whether a parent is voluntarily underemployed is a factual finding that we review
for clear error. Welsh v. Welsh, 775 N.W.2d 364, 370 (Minn. App. 2009). When reviewing
for clear error, we view the evidence in the light most favorable to the findings and “will
not conclude that a fact[-]finder clearly erred unless, on the entire evidence, we are left
with a definite and firm conviction that a mistake has been committed.” Kenney, 963
N.W.2d at 221 (quotations omitted). We do not reweigh the evidence, and we defer to
district court’s credibility determinations. See id. at 217; Sefkow, 427 N.W.2d at 210.
18
In his May 2025 motion to modify child support, father requested a modification of
child care support based on a reduction in the cost of child care. In his amended motion,
father requested the same modification to child care support as well as a modification of
his basic child support obligation based on his alleged reduction in income. As to the
modification of child care support, father argued that he believed that the child was now in
school, which he believed would reduce the cost of child care, and he asserted that mother
provided no documentation of child care expenses. As to the modification of basic child
support, he argued that he was earning only $1,200 a month and was enrolled in a master’s
program to become a CPA.
In denying his request to modify child support, the district court noted that it
previously found father was voluntarily underemployed in its initial decree and that father
previously sought a modification to child support based on his enrollment in the same
master’s program. The district court also observed that an individual is not voluntarily
underemployed if they show that underemployment is based on a bona fide career change.
But the district court reasoned that father’s affidavits failed to show that his career change
outweighs the adverse effects of the diminished income and that the amount of expected
earnings was also unknown. The district court also explained that, although child support
may be modified based on a change in child care expenses, father provided no information
to establish the changed cost of child care. And the district court therefore concluded that
father failed to carry his burden to demonstrate a substantial change in circumstances that
would support a modification of child support.
19
On appeal, father contends that the district court abused its discretion by denying
his request to modify child support. He argues that the district court erroneously
determined that father’s enrollment in the CPA program was not a bona fide career change,
that the district court erroneously calculated his income in the initial decree and relied on
that finding in denying his present request, and that the district court erred in denying his
request for a modification to child care support based on the change in child care costs.
We address each of father’s arguments in turn.
Bona Fide Career Change
Father first argues that the district court erred by finding that his pursuit of a master’s
degree was not bona fide career change.
The district court found that father failed to show that his career change outweighed
the adverse effects of the diminished income and the amount by which father expected his
earnings to increase based on his new career. That finding is supported by the record—
nothing in father’s affidavit attached to his amended motion or his May 2025 child-custody
related motion, adequately addressed these matters. Although father’s amended motion
included a statement that he expected to receive an increase in income upon becoming a
licensed CPA, the supreme court has held that a parent does not establish that
underemployment will lead to an increase in income when t he “assessment of his future
earnings is entirely speculative.” Putz, 645 N.W.2d at 353. Here, father’s assertion that
he expects to receive an increase in income, without anything more than his own assertions,
is merely speculative.
20
Because we are not left with a definite and firm conviction, based on this record,
that a mistake has been made, the district court did not clearly err by finding that father’s
pursuit of his CPA license was not a bona fide career change. We therefore discern no
abuse of discretion in the district court’s reliance on that finding to determine that father
failed to carry his burden to show a substantial change in his financial circumstances
warranting a modification to child support under Minn. Stat. § 518A.39, subd. 2(a)(1).
Erroneous Calculation in Initial Decree and Present Order
Father also argues that the district court erroneously calculated his income in the
initial decree and unfairly relied on that finding in its present order.
But father cites no legal authority that would support his argument. See
Dieseth v. Calder Mfg. Co., 147 N.W.2d 100, 103 (Minn. 1966) (stating that “[e]ven
though the decision of the trial court in the first order may have been wrong, if it is an
appealable order it is still final after the time for appeal has expired”); Dailey v. Chermak,
709 N.W.2d 626, 631 (Minn. App. 2006) (applying this aspect of Dieseth in a family-law
appeal), rev. denied (Minn. May 16, 2006). Father’s argument on this issue is not properly
before us, and we decline to address it. See Ganguli, 512 N.W.2d at 919 n.1; Melina, 327
N.W.2d at 20.
Modification to Child Care Support
Father lastly argues that the district court erred by denying his request to modify
child care support based on the alleged change in child care costs. H e argues that the
district court erred because he carried his initial burden to show a substantial change in
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circumstances by alleging that the child was enrolled in school, and that mother provided
no documentation of ongoing child care costs under Minn. Stat. § 518A.40 (2024).
Father’s arguments fail to persuade us that the district court abused its discretion in
denying his request to modify child care support. First, although father alleged that the
child was now in school, which he believed would reduce the cost of child care, father
provided no specific allegations beyond these mere assertions that the costs of child care
had decreased. Father therefore failed to carry his burden of proving both that there has
been a substantial change in circumstances and that the change makes the existing order
unreasonable and unfair. See Hecker, 568 N.W.2d at 709.
Second, although father generally alleged in his May 2025 motion and amended
motion that mother had failed to provide documentation of child care costs, father did not
make the argument under Minn. Stat. § 518A.40 in those motions. Because father argues
for the first time before this court that mother failed to provide documentation regarding
child care costs under section 518A.40, and the district court did not consider whether
mother failed to provide documentation under section 518A.40, this court may not consider
his arguments on this issue. See Thiele, 425 N.W.2d at 582.
In sum, father failed to carry his burden to show that the district court abused its
discretion in denying father’s request to modify child support or child care support. See
Midway Ctr. Assocs., 237 N.W.2d at 78. We therefore affirm the district court’s denial of
father’s request to modify child support.

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IV. The district court did not clearly err by finding that father presented no
credible evidence in support of his motion regarding the safety of the child.

Father next challenges the district court’s factual findings related to his request for
an order regarding the child’s safety.
We review a district court’s findings of fact for clear error, “giving deference to the
district court’s opportunity to evaluate witness credibility.” Goldman v. Greenwood, 748
N.W.2d 279, 284 (Minn. 2008). “Findings of fact are clearly erroneous where an appellate
court is left with the definite and firm conviction that a mistake has been made.” Id.
(quotation omitted).
In his amended motion, father requested an order prohibiting mother from allowing
the child to be alone with her brother and prohibiting the child from traveling to Saudi
Arabia. In denying father’s request, the district court found that father presented no
credible evidence that mother’s brother is a danger to the child or that the child must be
prohibited from traveling to Saudi Arabia with either parent. The district court therefore
denied father’s request.
On appeal, father argues that the district court ignored credible evidence that the
brother was a danger to the child and that the child should be prohibited from traveling to
Saudi Arabia. He thus asserts that the district court clearly erred by finding that he
presented no credible evidence.
To the extent that he argues that the district court ignored his credible evidence, he
essentially asks this court to reweigh the evidence on appeal, which this court cannot do.
See Sefkow, 427 N.W.2d at 210. Based on our review of the record, we are not left with a
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definite and firm conviction that a mistake has been made, and we discern no clear error in
the district court’s finding that father presented no credible evidence that the brother was a
danger to the child and that the child should be prohibited from traveling to Saudi Arabia.
We affirm the district court’s denial of father’s request for an order prohibiting
mother from allowing the child to be alone with her brother and prohibiting the child from
traveling to Saudi Arabia.
V. The district court did not abuse its discretion by denying father’s request for
tax-dependency-exemption status.

Father next challenges the district court’s denial of his request for a tax-dependency
exemption under Minn. Stat. § 518A.38 (2024).
We review a district court’s allocation of an income-tax dependency exemption for
an abuse of discretion. See Ludwigson v. Ludwigson, 642 N.W.2d 441, 449 (Minn. App.
2002) (“The allocation of federal-tax exemptions is within the [district] court’s
discretion.”). “A district court abuses its discretion by making findings of fact that are
unsupported by the evidence, misapplying the law, or delivering a decision that is against
logic and the facts on record.” Woolsey, 975 N.W.2d at 506 (quotation omitted).
Under Minn. Stat. § 518A.38, subd. 7, the district court “may allocate income tax
dependency exemptions” in some cases. But the statute further provides that “[a] party
with less than ten percent of court-ordered parenting time shall not be entitled to receive a
dependency exemption except by agreement of the parties.” Minn. Stat. § 518A.38, subd.
7(d).
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In his amended motion, father sought tax exemption status on an alternating annual
basis. In denying father’s request, the district court observed that the initial decree granted
mother the ability to claim the child as a dependent for tax purposes. The district court
also explained that father did not allege that the parties have an agreement to alternate tax
exemption status and that father continues to have less than ten percent parenting time.
The district court therefore held that father was not entitled to the tax-dependency
exemption.
On appeal, father does not dispute that he has less than ten percent parenting time.
Instead, he argues that the district court’s application of the statute was “[o]verly [r]igid”
and ignored the court’s “broader equitable powers in dissolution cases.” He asserts that
the district court “should have engaged in an analysis of which parent would derive the
greater financial benefit from the exemption” and that allocating the exemption to father
“[w]ould [p]romote the [c]hild’s [w]ell-[b]eing.”
Father’s arguments fail to persuade us that the district court abused its discretion in
denying his request for a tax-dependency exemption. The district court reasoned, based on
evidence in the record, that father continues to have less than ten percent parenting time.
Indeed, father acknowledges that he has not seen his child in 18 months. The district court
therefore correctly determined that father was not entitled to a tax-dependency exemption
under Minn. Stat. § 518A.38, subd. 7(d), because he maintains less than ten percent
parenting time. We discern no abuse of discretion in the district court’s determination. See
Woolsey, 975 N.W.2d at 506.
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In addition, father’s arguments that the district court’s application of the statute were
overly rigid and that the district court should have engaged in a different analysis are
unsupported by any citation to appropriate legal authority. 3 Father’s argument s on this
issue are not properly before us, and we decline to address them. See Ganguli, 512 N.W.2d
at 919 n.1; Melina, 327 N.W.2d at 20.
We conclude that the district court did not abuse its discretion by denying father’s
request for a tax dependency exemption under Minn. Stat. § 518A.38.
VI. We do not reach the merits of father’s due-process argument raised for the
first time on appeal.

Father next contends that the district court relied on factual inaccuracies and
translation errors in its orders and initial decree which violated father’s “due[-]process right
to a fair and accurate proceeding and renders the [district] court’s findings clearly
erroneous.”
Father’s amended motion, however, included no due-process claims. And the
district court’s orders from which father appeals did not consider whether father’s due -
process rights had been violated. As a result, this court may not consider his arguments on
this issue. See Thiele, 425 N.W.2d at 582; see also In re Welfare of C.L.L., 310 N.W.2d
555, 557 (Minn. 1981) (declining to address father’s due-process argument and noting that
appellate courts generally will not consider constitutional issues not raised below).

3 Father cites in his brief to Lilleboe v. Lilleboe, 453 N.W.2d 721 (Minn. App. 1990), for
the proposition that “tax exemptions ” are a “ component of the child support scheme
intended to benefit the child.” But Lilleboe does not discuss tax exemption status or the
broader equitable powers of the court. See id. at 721-24.

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We therefore decline to address father’s due-process arguments based on the alleged
factual inaccuracies and translation errors.
VII. We do not reach father’s service-related due-process argument raised for the
first time in his reply brief.

Finally, father contends that his due-process rights were violated because he did not
receive service of process of mother’s frivolous-litigant motion.
But father did not raise this issue in his principal brief on appeal. Instead, father
raises this argument for the first time in his reply brief. 4 We generally do not reach issues
raised for the first time in a reply brief. Emerson v. Sch. Bd. of Indep. Sch. Dist. 199, 809
N.W.2d 679, 687 (Minn. 2012). We therefore decline to address father’s service-related
due-process argument.
Affirmed.

4 We also note that father’s assertion that he did not receive service of mother’s frivolous-
litigant motion is not supported by the record. Although father’s attorney informed the
district court that father was unaware of mother’s frivolous-litigant motion until he retained
counsel, the record indicates that mother’s attorney filed an affidavit of service for her
frivolous-litigant motion and that father filed a document responding to mother’s frivolous-
litigant motion before retaining counsel.