Nakesha Laneice Brown, Nadiya Tinsley-Graham, Cyrus De’ondre Moore-Brown, Lexus Shiann Clark (Deceased) Below

This opinion is nonprecedential except as provided by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
A25-2075

Nakesha Laneice Brown, petitioner,
Respondent,

Nadiya Tinsley-Graham, petitioner,
Appellant,

Cyrus De’ondre Moore-Brown,
Respondent,

Lexus Shiann Clark (Deceased),
Respondent Below.

Filed September 8, 2026
Affirmed
Harris, Judge

Anoka County District Court
File No. 02-FA-24-196

Nakesha Laneice Brown, Andover, Minnesota (self-represented respondent)

Kathryn M. Lammers, Heimerl & Lammers, LLC, Minnetonka, Minnesota (for appellant)

Patricia A. Zenner, Zenner Law Office, Stillwater, Minnesota (guardian ad litem)

Considered and decided by Harris, Presiding Judge; Wheelock , Judge; and
Larson, Judge.
NONPRECEDENTIAL OPINION
HARRIS, Judge
In this third-party custody dispute, maternal grandmother challenges the district
court’s order granting sole legal custody of the parties’ grandchild to paternal grandmother.

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Maternal grandmother argues that (1) the district court erred in its application of Minnesota
Statutes section 257C.03 (2024), (2) the district court abused its discretion by awarding
sole legal custody of grandchild to paternal grandmother, (3) the district court abused its
discretion when it analyzed the best-interests factors under Minnesota Statutes section
257C.04, subdivision 1 (2024), (4) the district court abused its discretion by relying on
father’s inferred custody preference, and (5) the cumulative effect of these errors requires
reversal. Because we conclude that the district court properly applied Minnesota Statutes
section 257C.03 and acted within its discretion, we affirm.
FACTS
This case concerns the custody of C.B., born in 2017. C.B. is the son of respondent
Lexus Shiann Clark (mother) and respondent Cyrus De’Ondre Brown (father). Appellant
Nadiya Tinsley-Graham is the maternal grandmother of C.B. Respondent Nakesha Laneice
Brown is the paternal grandmother of C.B.
Mother passed away in July 2020, and father was awarded sole legal and sole
physical custody of C.B. Following mother’s death, father and C.B. resided with Brown
at her residence in Anoka County. Brown provided care for C.B. and coordinated times
for Tinsley-Graham to visit C.B. When C.B. started preschool, father was living with his
girlfriend in Hennepin County while C.B. lived with Brown in Anoka County. Father
visited C.B. in the evenings and put C.B. to bed. Father also took C.B. to school and
maintained consistent communication with C.B. via telephone and FaceTime.
In June 2023, C.B. lived with father and father’s girlfriend in Hennepin County.
Around this time, father was arrested on multiple occasions for violating a domestic abuse

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no contact order. While incarcerated, father asked Tinsley-Graham, who also resided in
Hennepin County, to care for C.B. and C.B. began residing with Tinsley-Graham later that
summer. Father executed a delegation of parental authority, which gave Tinsley-Graham
permission to care for and make decisions on behalf of C.B. for one year.1 Such decisions
included, but were not limited to, C.B.’s medical treatment, school enrollment, supervision,
care, and housing for C.B. Tinsley-Graham helped father enroll C.B. in elementary school
in Hennepin County for the fall of 2023.
In October 2023, father suffered an anoxic brain injury while he was incarcerated.
Father became permanently incapacitated and can no longer care for himself. In
February 2024, Brown filed a petition for third-party custody seeking sole legal and
physical custody of C.B. Brown also filed an emergency guardian petition on behalf of
father.
Father was eventually discharged from the hospital and started living with Bro wn
in her home, where he received full-time in-home care. Brown and Tinsley-Graham agreed
that C.B. would visit Brown’s residence over spring break so C.B. could spend time with
father. C.B. continued to visit father at Brown’s residence every other weekend through
the spring of 2024.
Father’s home-health nurse was present during C.B.’s visits. The nurse reported
that C.B. would sit on the bed with father and tell father about his day. C.B. would also
play video games and describe the game to father. She reported that C.B. seemed genuinely

1 The delegation of parental authority expired on August 23, 2024.

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happy and enjoyed spending time with father. The nurse also observed that father looked
attentively at C.B. When C.B. was around, father would try to move his arms to hug C.B.
and would attempt to move his mouth to speak to C.B.
At the end of the school year, Brown contacted Tinsley-Graham to discuss C.B.’s
living arrangements. Brown believed that C.B. should reside at her residence with his
father and half-brother. Brown also suggested that C.B. should enroll in a school in Anoka
County. Tinsley-Graham did not agree and informed Brown that she had delegation of
parental authority over C.B. until August 23, 2024.
From then on, the relationship between Brown and Tinsley-Graham began to
deteriorate. For example, on June 25, 2024, Brown contacted Tinsley -Graham to pick up
C.B later that afternoon. Brown was planning on celebrating C.B.’s birthday with his
father’s side of the family. Tinsley-Graham stated, “It will not be today.” Brown explained
that the parties had a conversation and that each side of the family should have an
opportunity to celebrate C.B.’s birthday with him. Tinsley-Graham stated that Brown
“made a decision” to which she did not agree.
On June 28, 2024, Brown asked Tinsley-Graham about whether she could see C.B.
over the weekend. Tinsley-Graham did not respond.
On July 1, 2024, Brown asked Tinsley- Graham when she could pick up C.B. for a
visit with father. Tinsley-Graham replied by saying “When I get some things figured out.
I cannot allow you to say what can and can’t happen in my household.” Tinsley -Graham
also asked Brown to establish a visitation schedule for C.B. Brown and Tinsley -Graham
then argued over father’s wishes for C.B. On July 26, 2024, Tinsley-Graham filed a

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petition for third-party custody of C.B. Tinsley-Graham sought sole legal and sole physical
custody of C.B.
On August 30, 2024, Brown contacted Tinsley-Graham to arrange a time to pick up
C.B. to visit father. Tinsley-Graham did not respond. The next day, Brown asked Tinsley-
Graham “When and where can [C.B.] be picked up today?” Tinsley-Graham stated, “He
won’t.” Brown insisted that C.B. be returned to his father. Tinsley-Graham replied saying:
“[C.B] will be starting school on Tuesday and [father] is the one that allowed/asked [C.B.]
to be with me and take care of him.”
Approximately one year later, the matter proceeded to trial. Tinsley-Graham was
represented by counsel. Brown did not appear. 2 Tinsley-Graham testified that she would
like C.B. to continue living with her but acknowledged that she would still like C.B. to
have a relationship with father’s side of the family. Tinsley-Graham proposed that C.B.
live with her during the school year but that C.B. could spend one weekend per month with
Brown. C.B. could also visit Brown during school breaks. During the summer months,
Tinsley-Graham suggested that Brown would have two weeks per month with C.B. to take
him on trips.
The district court also appointed a guardian ad litem (GAL) on behalf of father, who
testified as a witness. The GAL believed that it was in father’s best interest to spend as
much time with C.B. as possible and for C.B. to reside with father at Brown’s r esidence.

2 Brown’s counsel filed a notice of withdrawal one week before trial. The district court
acknowledged this circumstance and attempted to contact Brown. The court also left the
record open for two weeks for Brown to respond as to why she did not appear or explain
her position.

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The GAL also noted that both Brown and Tinsley-Graham provided love and care to C.B.
and requested that Brown and Tinsley-Graham share joint legal and physical custody.
The district court denied Brown’s and Tinsley-Graham’s petitions for sole legal and
sole physical custody. It also denied father’s request for Brown and Tinsley-Graham to
share joint legal custody. The district court expressed concern over Tinsley-Graham’s
ability and willingness to ensure that C.B. maintained contact with father’s side of the
family. The district court “ha[d] no belief that Petitioner Graham c[ould] cooperate in
making major life decisions regarding school, medical, or cultural matters at this time.” It
also recognized that father and C.B. shared a strong and loving bond that should be fostered
and maintained. Thus, the district court awarded sole legal custody to Brown and identified
Brown’s home as C.B.’s primary residence.
The district court also acknowledged that father would want Brown and Tinsley-
Graham to have an active role in C.B.’s life, and that both parties should have “significant
visitation.” Accordingly, the district court granted father’s request and awarded Brown
and Tinsley-Graham joint physical custody.
Tinsley-Graham appeals.
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DECISION
Tinsley-Graham raises five arguments on appeal. First, she argues that the district
court misapplied Minnesota Statutes section 257C.03 by awarding Brown sole legal

3 In December 2025, this appeal was referred to the Family Law Appellate Mediation
Program. The appeal was stayed pending mediation. None of the issues were resolved,
and the stay was subsequently dissolved.

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custody despite Brown’s failure to appear at trial. Second, she claims that the district court
abused its discretion by awarding Brown sole legal custody rather than joint legal custody.
Third, Tinsley-Graham contends that the district court improperly analyzed the statutory
best-interests factors under Minnesota Statutes section 257C.04 (2024). Fourth, she argues
that the district court erroneously relied on father’s wishes despite his incapacity. Finally,
Tinsley-Graham asserts that the cumulative effect of several alleged factual errors requires
reversal. We address each argument in turn.
I. The district court did not err in its application of Minnesota Statutes
section 257C.03.

Tinsley-Graham first argues that the district court erred in its application of
Minnesota Statutes section 257C.03 by awarding sole legal custody of C.B. to Brown.
More specifically, she argues that because Brown did not appear at trial to testify or
otherwise support her petition for third-party custody, her requests lacked evidentiary
support, and her petition should have been denied. We are not persuaded.
An individual other than a child’s parent may petition the district court for custody
of the child as an interested third party. Minn. Stat. § 257C.03, subd. 1. Third -party
custody proceedings occur in two stages. Lewis -Miller v. Ross, 710 N.W.2d 565, 569-70
(Minn. 2006). At the first stage, the petitioner must submit a valid petition and the
supporting affidavits alleging facts that meet the statutory requirements, which, if true,
would allow the district court to grant the petitioner third-party custody. Id. at 569. To
obtain custody as an interested third party, a petitioner has the burden to establish by clear
and convincing evidence that

8
(i) the parent has abandoned, neglected, or otherwise
exhibited disregard for the child’s well-being to the extent that
the child will be harmed by living with the parent;
(ii) placement of the child with the individual takes
priority over preserving the day-to-day parent-child
relationship because of the presence of physical or emotional
danger to the child, or both; or
(iii) other extraordinary circumstances[.]

Minn. Stat. § 257C.03, subd. 7(a)(1). A petitioner seeking custody as an interested third
party must also prove by the preponderance of the evidence that third-party custody is in
the child’s best interests and that the third party has not been convicted of any crimes listed
under Minnesota Statutes section 518.179 (2024). Id., subd. 7(a)(2)-(3). Accordingly, at
the first stage of a proceeding in which a petitioner seeks custody as an interested third
party, the petitioner must submit a valid petition and the supporting affidavits alleging facts
that, if true, would show these circumstances to be present. If the petitioner does so, then,
at the second stage of the proceeding , the district court holds an evidentiary hearing and
then addresses whether the petitioner proved the existence of the facts alleged in the
petitioner’s petitioner and supporting affidavits. Lewis-Miller, 710 N.W.2d at 569.
Here, the district court determined that there was clear and convincing evidence of
an extraordinary circumstance because C.B.’s mother was deceased and because father,
who was C.B.’s primary caregiver, became permanently incapacitated and was no longer
able to care for C.B. On appeal, Tinsley-Graham does not challenge this determination or
the district court’s findings.
Both Tinsley-Graham and the GAL on behalf of father appeared and testified at the
evidentiary hearing. The GAL acknowledged that father relied on Brown and Tinsley-

9
Graham to care for C.B. The GAL also observed that C.B.’s presence was stimulating and
helpful for father’s healing process. The GAL believed it was in father’s best interest for
C.B. to reside with Brown, but that Brown and Tinsley- Graham should share joint legal
and physical custody of C.B. The district court ultimately denied Brown’s petition for third
party custody because Brown failed to appear at the evidentiary hearing to support her
requests.
The district court granted father’s request by awarding Brown and Tinsley-Graham
joint physical custody but determined that awarding sole legal custody of C.B. to Brown
was in C.B.’s best interest.
Here, the record demonstrates that the district court did not grant Brown’s requests
for sole legal and physical custody of C.B. Rather, the district court granted father’s request
to award Brown and Tinsley-Graham shared physical custody and liberal parenting time
before determining that it was in C.B.’s best interest for Brown to have sole legal custody.
Tinsley-Graham does not identify any misapplication of section 257C.03. Rather,
she appears to disagree with the district court’s ultimate custody determination. Although
she contends that Brown’s failure to appear at the evidentiary hearing required denial of
Brown’s request for custody, the record establishes that the district court did, in fact, deny
Brown’s third-party custody petition because Brown failed to appear and support her
requests. In addition, the district court granted father’s request regarding custody after
considering the testimony presented, the GAL’s recommendations, and the evidence
admitted at the hearing. The district court then determined that awarding Brown sole legal
custody, while providing for shared physical custody and parenting time, was in C.B.’s

10
best interest. Because the district court did not award Brown the relief sought in her third-
party custody petition under Minnesota Statutes section 257C.03 but instead ruled on
father’s custody request based on the evidence before it, Tinsley-Graham’s argument does
not demonstrate that the district court misapplied the statute.
Tinsley-Graham’s argument that father lacked capacity to participate in the
proceedings because he did not file an answer and counterpetition is likewise unpersuasive.
Father had sole legal and sole physical custody of the minor child before these proceedings.
Due to father’s permanent incapacitation, the district court appointed a GAL to advocate
on his behalf. As discussed in section IV of this opinion, the GAL represented father’s
interests throughout the proceedings, including presenting father ’s position regarding
custody. Accordingly, father’s failure to personally file an answer and counterpetition did
not deprive him of the ability to participate in the proceedings through his court-appointed
representative or otherwise demonstrate that the district court misapplied the statute.
Accordingly, the district court did not err in its application of section 257C.03.
II. The district court acted within its discretion by awarding sole legal custody of
C.B. to Brown.

Next, Tinsley-Graham challenges the district court’s conclusion that joint legal
custody with Brown was not a feasible option. Tinsley-Graham contends that the district
court’s finding that she could not cooperate with Brown in making major life decisions
regarding school, medical, or cultural matters on behalf of C.B. was unsupported by the
record. We disagree.

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“This court’s review of a district court’s third-party custody determination is limited
to whether the court abused its discretion.” In re Custody of A.L.R., 830 N.W.2d 163, 166
(Minn. App. 2013). “A district court abuses its discretion by making findings unsupported
by the evidence or by improperly applying the law.” Id. (quotation omitted). We will not
set aside the district court’s findings of fact unless they are clearly erroneous.” Id.
The district court determined that it was in C.B.’s best interest to award sole legal
custody to Brown. The district court reasoned that while Brown and Tinsley-Graham were
both suitable caregivers and could properly care for C.B., it was “concerning” that Tinsley-
Graham did not facilitate contact between C.B. and Brown after their disagreement. It
found that Tinsley-Graham would ignore Brown’s messages and was willing to restrict
contact between C.B. and his paternal family members, including father. The district court
expressed concern that Tinsley-Graham was “not putting [C.B.’s] best interest in
maintaining a strong familial connection with his paternal family” despite her differences
with Brown.
The district court also found that Tinsley-Graham recommended “an unnecessarily
restrictive parenting time schedule that [was] not in [C.B.’s] best interest and would
significantly reduce his interaction with his father and his paternal grandmother and
paternal relatives, including his brother.” It noted that Tinsley-Graham’s recommended
visitation schedule “would result in significant periods of no contact” between C.B. and
father. And it concluded that joint legal custody was not in C.B.’s best interest because it
would invite conflict between Brown and Tinsley-Graham.

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The district court’s findings are well supported by the record. On June 25, Brown
contacted Tinsley-Graham to pick up C.B. later that afternoon to celebrate C.B.’s birthday.
Tinsley-Graham stated, “It will not be today.” When Brown explained that the parties had
previously had a conversation and that each side of the family should have an opportunity
to celebrate C.B.’s birthday with him, Tinsley-Graham stated that Brown “made a decision
about [Tinsley-Graham’s] household” to which she did not agree.
On June 28, Brown contacted Tinsley-Graham asking to visit C.B. over the
weekend. Tinsley-Graham did not respond. On July 1, Brown asked Tinsley-Graham
when she could pick up C.B. for a visit with father. Tinsley-Graham replied by saying ,
“When I get some things figured out. I cannot allow you to say what can and can’t happen
in my household.” On August 30, Brown contacted Tinsley-Graham to arrange a time to
pick up C.B. to visit his father. Tinsley- Graham again did not respond. On August 31,
Brown asked Tinsley-Graham, “When and where can C.B. be picked up today?” Tinsley-
Graham stated, “He won’t.”
Tinsley-Graham argues that there is no evidence in the record to suggest that she
did not meet C.B.’s educational, medical, or cultural needs. She also asserts that, even if
conflict existed with Brown, she still encouraged contact with father. We are not
convinced.
The district court did not find that Tinsley-Graham failed to meet C.B.’s
educational, medical, or cultural needs. The district court stated numerous times that
Tinsley-Graham is a suitable caregiver who properly provides for C.B.’s needs. Indeed,
the district court reiterated that it was “not concerned about [Tinsley- Graham’s] ability to

13
care for [C.B.].” Instead, the district court expressed concern over Tinsley-Graham’s
“ability and willingness to ensure [C.B.] maintains contact with his paternal family,
including his father and paternal half-brother.”
Furthermore, the record directly contradicts Tinsley-Graham’s assertion that she
encouraged contact between C.B. and father. At trial, the district court asked Tinsley-
Graham how she ensured C.B. was maintaining contact with his paternal side of the family
while she had custody of C.B. Tinsley-Graham stated that she “gave him an iPad to be
able to communicate with them.” She also stated that she encouraged communication with
C.B.’s paternal family by giving him a cellphone. The district court found that “[s]imply
providing a phone to a young child is not facilitating contact,” and that it was “unreasonable
to assume a young child should bear the responsibility for maintaining contact with family
members.”
Therefore, we conclude that the district court acted within its discretion by awarding
Brown sole legal custody of C.B.
III. The district court acted within its discretion when analyzing the best-interests
factors under Minnesota Statutes section 257C.04, subdivision 1.

Tinsley-Graham next argues that the district court abused its discretion when
analyzing the best-interests factors because its decision to change C.B.’s primary residence
“rest[ed] largely on adult conflict and text-message disputes between [Tinsley-Graham]
and respondent Brown.” We are not persuaded.
“If two or more parties seek custody of a child, the [district] court must consider
and evaluate all relevant factors in determining the best interests of the child.” Minn. Stat.

14
§ 257C.04, subd. 1. Section 257C.04 identifies twelve factors the district court must
consider. Id., subd. 1(a)(1)-(12). The district court may not rely on one factor. Minn. Stat.
§ 257C.04, subd. 1(b). Rather, “[t]he court must make detailed findings on each of the
factors and explain how the factors led to its conclusion s. Id. “Caselaw ‘leaves scant if
any room for an appellate court to question the [district] court’s balancing of best-interest
considerations.’” Ewald v. Nedrebo, 999 N.W.2d 546, 551 (Minn. App. 2023) (quoting
Vangsness v. Vangsness, 607 N.W.2d 468, 477 (Minn. App. 2000)), rev. denied (Minn.
Feb. 28, 2024).
Tinsley-Graham does not assert that the district court’s best-interest s findings are
unsupported by the record. She also does not identify a specific best interest factor that the
district court failed to consider. Instead, Tinsley-Graham appears to be dissatisfied with
the district court’s outcome. But this court “will not disturb the district court’s decision
unless it abused its discretion by making a decision unsupported by the facts” found by the
district court. Ewald, 999 N.W.2d at 552. And the district court’s factual findings are well
supported.
In awarding third-party custody to Brown, the district court analyzed each of the
best-interests factors under section 257C.04 and made detailed findings for each factor.
The district court considered factors including, but not limited to, father’s wishes, the
intimacy of C.B.’s relationship with Brown and Tinsley-Graham, C.B.’s relationship with
his half-brother and extended family members, and the importance of maintaining a
relationship with father.

15
After considering each factor, the district court determined that awarding Brown
sole legal custody was in C.B.’s best interest . It reasoned that father and C.B. shared a
“strong and loving bond” prior to father’s incapacitation, and that their relationship should
continue to be fostered and maintained. It also found that father would want Brown and
Tinsley-Graham to each have a significant role in C.B.’s life. Moreover, the district court
expressed concern over Tinsley-Graham’s “ability and willingness” to facilitate contact
with C.B.’s paternal family members and reasoned that merely providing C.B. with a phone
or an iPad without further involvement from Tinsley-Graham was insufficient. The district
court concluded that while father would like Tinsley-Brown to aid in C.B.’s educational,
medical, and cultural needs, joint legal custody was “not a viable option currently.”
Thus, because the district court considered the relevant factors to determine the best
interests of C.B., made detailed findings on each factor that were supported by the record,
and explained how the factors led to its conclusions, we discern no abuse of discretion.
IV. The district court acted within its discretion by considering father’s wishes
before awarding third-party custody to Brown.

Tinsley-Graham argues that because father’s medical incapacitation limits his
ability to clearly articulate his wishes, the district court abused its discretion by relying on
father’s “inferred preference.” Tinsley-Graham notes that “father did not testify or in any
way participate in these proceedings because [of] his medical condition,” and suggests that
any inference about father’s current custodial preference is “purely speculative.” We
disagree.

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“A party who is an infant or is incompetent and is not so represented shall be
represented by a guardian ad litem appointed by the court in which the action is pending
or is to be brought.” Minn. R. Civ. P. 17.02(a). “[T]he representative may sue or defend
on behalf of such party.” Id.
In August 2024, the district court issued an order appointing a GAL on behalf of
father “to investigate [father’s] circumstances and protect his rights.” The district court
acknowledged that father was a party to this action and determined that a GAL was
necessary to ensure that the outcome was fair and reasonable. The district court instructed
the GAL to conduct an independent investigation and to “advise the Court as to what she
believes are [father’s] best interests.” The GAL reviewed father’s medical records, court
case files, and interviewed Brown, Tinsley- Graham, father’s family members, father’s
home-health nurse, and staff members at C.B.’s school. The GAL “consider[ed] all
relevant information pertaining to the case before the court and opine[d] on what [father]
would be requesting of the court if he were capable; or what is in the best interest of [father]
to recommend to the [district] court.”
The GAL determined that it was in father’s best interest to reside with C.B. at
Brown’s residence. She noted that prior to the accident, father always maintained contact
with C.B. Following the accident, the GAL noted that father is more active with hand,
head, and eye movements when C.B. is around. She reported that father would look at
C.B., try to move his arms to hug C.B., and attempt to move his mouth to speak to C.B.
She also stated that father’s body is more relaxed when C.B. is present. Additionally, the
GAL reported on father’s relationship with Brown and Tinsley-Graham. She noted that

17
father trusted both Brown and Tinsley- Graham to care for C.B. and believed that father
would want C.B. to spend time with both grandparents.
Here, the GAL conducted a thorough, independent investigation before making her
recommendation for what she believed father would have requested, if able, and what she
believed would be in father’s best interest. There is no evidence to suggest that father’s
wishes or interests were based on pure speculation. Moreover, the record does not support
Tinsley-Graham’s assertion that the district court’s determination was substantially
influenced by father’s “inferred preference.” In addition to the GAL’s report, the district
court considered evidence in the record, exhibits, and the best-interests factors under
Minnesota Statutes section 257C.04, subdivision 1.
Accordingly, the district court did not abuse its discretion by considering father’s
wishes before awarding Brown sole legal custody of C.B.
V. Tinsley-Graham’s cumulative-errors argument lacks merit.

Tinsley-Graham lastly argues that the district court made several unsupported
factual findings, and that the cumulative effect of these errors requires reversal. She
contends that the district court erred in finding that joint legal custody was not a viable
option because C.B. was “doing well” in her care, his educational needs were met, and she
facilitated ongoing contact between C.B. and father.
To support her contention, Tinsley -Graham relies on this court’s decision in
Vangsness, 607 N.W.2d at 471, and argues that, “where multiple deficiencies permeate a
custody order, reversal is required because confidence in the outcome has been
undermined.” We are not convinced.

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In Vangsness, wife sought a new trial after the district court awarded husband
physical custody of their children. 607 N.W.2d at 471. Wife asserted that the district
court’s findings of fact were unsupported by the record. Id. at 472. We held that in order
to successfully challenge a district court’s factual findings, “the party challenging the
findings must show that despite viewing that evidence in the light most favorable to the
[district] court’s findings . . . the record still requires the definite and firm conviction that
a mistake was made.” Id. at 474.
Tinsley-Graham’s reliance on Vangsness is misplaced. Vangsness provides that a
party challenging a district court’s factual findings must identify evidence in the record to
demonstrate that the findings are clearly erroneous. Vangsness does not stand for the
proposition that “where multiple deficiencies permeate a custody order, reversal is required
because confidence in the outcome has been undermined.” Notably, Minnesota courts have
not adopted the cumulative-error test in civil cases. See Hall v. Pipestone, LLC,
No. A19-1621, 2020 WL 1845521, at *9 (Minn. App. Apr. 13, 2020) (stating that
“appellate courts have only developed and applied the cumulative-error doctrine in
criminal cases”); Minn. R. Civ. App. P. 136.01, subd. 1(c) (stating that “nonprecedential
opinions may be cited as persuasive authority”).
Even assuming Tinsley-Graham properly relied on Vangsness, she has not
established that the district court’s factual findings regarding sole legal custody were
clearly erroneous. Evidence in the record demonstrates that, on several occasions, Tinsley-
Graham limited Brown’s visitation with C.B. and failed to adequately facilitate contact

19
between C.B. and father. Because we conclude that the district court’s factual findings
were supported by the record, reversal is not warranted.
In sum, the district court properly applied Minnesota Statutes section 257C.03,
made detailed findings addressing the statutory best-interests factors under Minnesota
Statutes section 257C.04, subdivision 1, and acted within its broad discretion in awarding
Brown sole legal custody of C.B.
Affirmed.