Cited by
Opinions in Minnesota that cite Marriage of Harkema v. Harkema, 474 N.W.2d 10.
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In the Marriage of:
Minn. Ct. App. 2025
In one case, this court reversed for an evidentiary hearing because the district court “already found a change in circumstances and modification is in the [children’s] best interest.”
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In re the Marriage of:
Minn. Ct. App. 2024
is also a recognized sign of present endangerment”); (concluding district court abused its discretion by determining that affidavits expressing children’s fear of custodial parent did not indicate possibility of endangerment).
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In Re the Custody of: J. B. D., Jason A. Duenes, petitioner, Appellant,
Minn. Ct. App. 2021
at 232; , cited in Amarreh, d at 232, for the proposition that, when there is a dispute as to whether a child’s present en vironment endangers emotional development “an evidentiary hearing would be helpful and is justified.” The district court’s order reflects bot h its view that appella
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In re the Marriage of: Maria Rothen, petitioner, Respondent,
Minn. Ct. App. 2019
-14 (Minn. App. 1991) (concluding father was entitled to an evidentiary hearing when affidavits alleged that the children were afraid of stepfather due to his yelling, throwing things, hitting walls, and driving like a maniac).
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In re the Marriage of:
Minn. Ct. App. 2019
tion of such abuse is supported by some evidence, an evidentiary hearing is appropriate.” Tarlan, d at 923-24 (citing Abbott v. Abbott , -69 (Minn. 1992) (reversing denial of an evidentiary hearing when mother’s history of throwing children out 11 of house created stress and anxiety in anticipation of being thrown out again in the future); Harkema v. Harkema , (reversing denial of an evidentiary hearing where appellant made allegations of emotional abuse by stepfather who would yell and throw ob
- Amarreh v. Amarreh 918 N.W.2d 228 Minn. Ct. App. 2018
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Amarreh v. Amarreh
918 N.W.2d 228
Minn. Ct. App. 2018
See Harkema v. Harkema , , 14 (Minn. App. 1991) ("Where some dispute exists as to whether the present environment endangers the [children's] emotional development, an evidentiary hearing would be helpful and is justified.").
- Darick Joseph Waguespack v. Jocelyn Alicia Merz Minn. Ct. App. 2016
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Darick Joseph Waguespack v. Jocelyn Alicia Merz
Minn. Ct. App. 2016
(stating that “the legislature likely intended to demand a showing of a significant degree of danger”); see, -14 (Minn. App. 1991) (holding that allegations of emotional abuse by stepfather who was “yelling, throwing things, hitting walls, and driving the car like a maniac” were sufficient to show endangerment).
- In re the Marriage of: Tamara Eileen Goemaat v. Andrew Joel Goemaat Minn. Ct. App. 2015
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In re the Marriage of: Tamara Eileen Goemaat v. Andrew Joel Goemaat
Minn. Ct. App. 2015
were so strong that no response by [r]espondent could possibly negate that showing.” In support of his argument, appellant cites Harkema v. Harkema, in which this court held that “[w]here the [district] court has issued an order for an evidentiary hearing, it cannot then sua sponte deny the evidentiary hearing without first giving the parties a chance to argue the case.”
- Marriage of Tarlan v. Sorensen 702 N.W.2d 915 Minn. Ct. App. 2005
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Marriage of Tarlan v. Sorensen
702 N.W.2d 915
Minn. Ct. App. 2005
See, e.g., Abbott, d at 868 -69 *924 (reversing denial of hearing when mother’s history of throwing children out of house created stress and anxiety in anticipation of being thrown out again in the future); (reversing denial of hearing where allegations of emotional abuse by stepfather who was “yelling, throwing things, hitting walls, and driving the car like a maniac”); (reversing denial of hearing where facts alleged might have established en
- Griese v. Kamp 666 N.W.2d 404 Minn. Ct. App. 2003
- Griese v. Kamp 666 N.W.2d 404 Minn. Ct. App. 2003
- Dalbec v. W.P.W. 653 N.W.2d 804 Minn. Ct. App. 2002
- In Re Weber 653 N.W.2d 804 Minn. Ct. App. 2002
- In Re Weber 653 N.W.2d 804 Minn. Ct. App. 2002
- Dalbec v. W.P.W. 653 N.W.2d 804 Minn. Ct. App. 2002
- Geibe v. Geibe 571 N.W.2d 774 Minn. Ct. App. 1997
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Geibe v. Geibe
571 N.W.2d 774
Minn. Ct. App. 1997
See, (reversing denial of hearing where stepfather abusive by yelling at stepsons, calling them stupid and dumb, and calling wife and boys’ father names, as well as throwing things, hitting walls, and driving “like a maniac”).
- Marriage of Ross v. Ross 477 N.W.2d 753 Minn. Ct. App. 1991
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Marriage of Ross v. Ross
477 N.W.2d 753
Minn. Ct. App. 1991
(allegations of emotional abuse of children by custodial parent’s spouse warranted hearing); (hearing required to investigate allegations of abuse, fear of the custodial parent and changes in the children’s attitude and behavior); cf. Roehrd