A26-0145 Nonprecedential Reversed Processed

In the Marriage of: Jeanne Mary Mohr v. Jesse David Mohr, County of Rice, Intervenor

Minnesota Court of Appeals · Filed August 24, 2026

The holding in the court’s own words

6 Because the district court misapplied the law by delegating its authority to mother to decide whether to allow father to file any motions and adopted mother’s proposed conclusion verbatim without making any findings, we conclude that the district court abused its discretion, requiring reversal.

Quoted verbatim from the opinion — no paraphrase, nothing generated. Not yet human-reviewed. How we find the holding.

Authorities cited

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Opinion text

This opinion is nonprecedential except as provided by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
A26-0145

In the Marriage of:

Jeanne Mary Mohr, petitioner,
Respondent,

vs.

Jesse David Mohr,
Appellant,

County of Rice,
Intervenor.

Filed August 24, 2026
Reversed
Reyes, Judge

Rice County District Court
File No. 66-FA-21-273

Britt Ackerman, Ackerman Law, Northfield, Minnesota (for respondent)

Dan Irwin, Irwin Law Office, PLC, Dundas, Minnesota (for appellant)

Considered and decided by Reyes, Presiding Judge; Ede, Judge; and Rasmusson,
Judge.

2
NONPRECEDENTIAL OPINION
REYES, Judge
Appellant-father challenges the district court’s order requiring him to obtain “the
advance consent and permission” of respondent-mother prior to father filing any motions.
We reverse.
FACTS
The action underlying this appeal began in February 2021 as a dissolution
proceeding between respondent- mother Jeanne Mary Mohr and appellant-father Jesse
David Mohr, who share three minor children. Later in 2021, the district court entered a
judgment and decree (J&D) dissolving the parties’ marriage, granting them joint legal and
joint physical custody, granting child support to mother, and setting a parenting-time
schedule. If future disputes arose, the J&D ordered the parties to “exhaust mediation as a
remedy before either party may apply to court for relief.”
The parties engaged in litigation over the next three years. At one point, mother
requested that father pay half of certain costs associated with their children’s
extracurricular activities, and both parties moved for conduct-based attorney fees based on
the request. The district court granted the extracurricular-costs request and denied both
parties’ attorney-fees requests. On several occasions following this decision, mother
requested that the district court find father to be in constructive civil contempt and grant
her conduct-based attorney fees. None of these requests resulted in the district court
finding father in contempt, but the district court granted mother conduct-based attorney
fees in one instance.

3
In August 2025, father moved for a modification of the parenting -time schedule.
Mother filed a responsive motion (“mother’s first motion”) requesting that the district court
(1) strike father’s motion for failure to comply with certain rules and court orders; (2) deny
father’s motion; and (3) grant mother attorney fees, whether conduct-based or need-based.
After an initial hearing, the district court continued the motion hearing to December 2025
and ordered that the parties engage in mediation.
The parties scheduled a remote mediation session for 9:00 a.m. one day in
November 2025. Mother and her counsel attended, but father and his counsel did not. At
12:20 p.m. that same day, mother filed a motion (“mother’s second motion”) to (1) strike
the December 2025 hearing; (2) grant the attorney-fees request from mother’s first motion;
and (3) “issue an Order that [father] may not file any future motions in this case without
the advance consent and permission of [mother].” Less than an hour later, at 1:05 p.m.,
father filed a notice of withdrawal of counsel.
Five days after the scheduled mediation, the district court filed a one-page order
granting mother’s second motion: It (1) struck the December 2025 motion hearing “for
[father’s] failure to engage in mediation”; (2) awarded mother attorney fees; and
(3) ordered that “[father] may not file any future motions in this case without the advance
consent and permission of [mother].”

4
Father appealed, and this court stayed the appeal pending mediation. The mediation
office then granted an exemption request, and we dissolved the stay. 1
DECISION
Father challenges the district court’s order requiring him to obtain “the advance
consent and permission” of mother to file future motions, arguing that “no Minnesota
statute, rule, or precedent authorizes” the district court to “delegate[] judicial authority to
a private adverse litigant.” We agree.
Generally, a district court has the “authority to enforce the Rules of Civil Procedure
and to maintain order and decorum in the operation of the court system.” In re Burns, 542
N.W.2d 389
, 390 (Minn. 1996). Appellate courts review the district court’s exercise of
this authority for an abuse of discretion. See id. (concluding that district court’s order
“constitute[d] a proper exercise of its 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).
We identify two primary defects in the district court’s order. First, the district court
did not provide any legal citation or authority for its decision to give mother all authority
to decide whether father could file any future motions. And we are unaware of any
authority allowing the district court to do so. Absent more, conferring on mother the

1 Because mother did not file an appellate brief, this court ordered that this appeal shall be
determined on the merits as provided in Minnesota Rule of Civil Appellate Procedure
142.03.

5
authority to decide whether to let father seek relief from the court constitutes a
misapplication of law and is against logic. See id.; cf. Smigla v. Schnell, 547 N.W.2d 102,
104-05 (Minn. App. 1996) (noting that, under Minn. R. Civ. P. 77.01, “[t]he district courts
shall be deemed always open for the purpose of filing any pleading or other proper paper”
and that under Minn. Stat. § 484.08 (1994) “district courts . . . shall be deemed open at all
times, except on legal holidays and Sundays” (quotations omitted)).
Second, the district court did not make any findings of fact or describe the reasons
supporting its decision to restrict father’s ability to file motions. Instead, the district court
merely adopted mother’s request verbatim. Generally, the “wholesale adoption of one
party’s” proposed conclusions “raises the question of whether the [district] court
independently evaluated each party’s testimony and evidence.” Bliss v. Bliss, 493 N.W.2d
583
, 590 (Minn. App. 1992), rev. denied (Minn. Feb. 12, 1993).
The district court has the authority to impose filing restrictions, such as when it
imposes sanctions or makes a frivolous-litigant determination. See Minn. R. Civ. P. 11.03
(sanctions); Minn. R. Gen. Prac. 9 (frivolous litigant). But in those situations, the district
court still has to provide findings to support its decision. See Minn. R. Civ. P. 11.03(c)
(“When imposing sanctions, the court shall describe the conduct determined to constitute
a violation of this rule and explain the basis for the sanction imposed.”); Minn. R. Gen.
Prac. 9.02(c) (“If the court determines that a party is a frivolous litigant and that security
or sanctions are appropriate, it shall state on the record its reasons supporting that
determination.”).

6
Because the district court misapplied the law by delegating its authority to mother
to decide whether to allow father to file any motions and adopted mother’s proposed
conclusion verbatim without making any findings, we conclude that the district court
abused its discretion, requiring reversal.2
Reversed.

2 Because we reverse on this ground, we need not address father’s additional arguments for
reversal. See, e.g., Westby v. Comm’r of Pub. Safety, 742 N.W.2d 443, 446 (Minn. App.
2007) (declining to address “remaining arguments” after reversing).