Cited by
Opinions in Minnesota that cite Marriage of Shirk v. Shirk, 561 N.W.2d 519.
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Michael Sarff, Respondent,
Minn. Ct. App. 2026
Indeed, it is well settled that “[c]ourts favor stipulations in dissolution cases as a means of simplifying and expediting litigation, and to bring resolution to what frequently has become an acrimonious relationship between the parties.”
- Shawn Paul Haren, Respondent, Minn. Ct. App. 2026
- In the Marriage of: Jarrid Daniel DeGolier v. Jessica Jean DeGolier Baron, ... Minn. Ct. App. 2026
- In the Marriage of: Jarrid Daniel DeGolier v. Jessica Jean DeGolier Baron, ... Minn. Ct. App. 2026
- In re the Marriage of: Todd Charles Bork v. Carolyn Mitsu Bork Minn. Ct. App. 2026
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In re the Marriage of: Todd Charles Bork v. Carolyn Mitsu Bork
Minn. Ct. App. 2026
(recognizing that, “even though we treat dissolution stipulations as contracts, they have unique features”); (stating that the “sole relief” from a stipulated J&D “lies in meeting the requirements of Minn. Stat. 7 § 518.145, subd.
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In Re the Marriage of:
Minn. Ct. App. 2025
2 (2024); see Shirk v. Shirk , (“The 6 sole relief from the judgment and decree lies in meeting the requirements of Minn. Stat. § 518.145, subd.
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In re the Marriage of:
Minn. Ct. App. 2025
atute section 518.145, subdivision 1 (2024), which provides that “[a] decree of dissolution of marriage or of legal separation is final when entered, subject to the right of appeal.” Generally, because of a desire for finality, “[r]elief from a judgment and decree of divorce based upon a stipulation of the parties is 7 available only under Minn. Stat. § 518.145 [(1996)].” 522 (Minn. 1977).
- A24-0675 Minn. Ct. App. 2025
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In re the Marriage of:
Minn. Ct. App. 2025
Stipulations in dissolution proceedings are favored by courts “as a means of simplifying and expeditin g litigation” and “are therefore accorded the sanctity of binding contract s.” Shirk v. Shirk, 9
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In re the Marriage of:
Minn. Ct. App. 2024
(holding that the stipulation “merges” with the final judgment and decree and that the “sole relief” from the judgment is to satisfy section 518.145, subdivision 2); see also Minn. Stat. § 518.552, subd.
- In re the Marriage of: Sarah Mae DeVille v. Darren Lee Hickey Minn. Ct. App. 2024
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In re the Marriage of: Sarah Mae DeVille v. Darren Lee Hickey
Minn. Ct. App. 2024
“Courts favor stipulations in dissolution cases as a means of simplifying and expediting litigation, and to bring resolution to what frequently has become an acrimonious relationship between the parties.”
- In re the Marriage of: Robert Thomas Nord, A v. Katherine Elizabeth Bowers, B, ... Minn. Ct. App. 2024
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In re the Marriage of: Robert Thomas Nord, A v. Katherine Elizabeth Bowers, B, ...
Minn. Ct. App. 2024
6 I. The district court did not abuse its discretion by denying wife’s motion to reopen the parties’ stipulated J&D. Wife first challenges the district court’s denial of her motion to reopen the stipulated J&D. The use of stipulations in dissolution proceedings is a judicially favored “means of simplifying and expediting litigation.”
- In the Matter of the Welfare of the Child of: J. M. B. (Mth) and I. C. R. … Minn. Ct. App. 2024
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In the Matter of the Welfare of the Child of: J. M. B. (Mth) and I. C. R. …
Minn. Ct. App. 2024
29, 2024); (“[W]hen a judgment and decree is entered based upon a stipulation, we hold that the stipulation is merged into the judgment and decree and the stipulation cannot thereafter be the target of attack by a party seeking relief from the judgment and decree.”).
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In re the Marriage of: Deborah Kay Schadewald, n/k/a Deborah Kay DeJong, petitioner, Respondent,
Minn. Ct. App. 2024
2 (2022) (setting forth limited grounds for reopening a judgment and decree); Shirk v. Shirk , (“The sole relief from the judgment and decree lies in meeting the requirements of Minn. Stat. § 518.145, subd.
- In re the Marriage of: Brenda Lee Christiansen v. Timothy Nels Christiansen, ... Minn. Ct. App. 2024
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In re the Marriage of: Brenda Lee Christiansen v. Timothy Nels Christiansen, ...
Minn. Ct. App. 2024
(distinguishing a “stipulation” as something that “represents the parties’ voluntary acquiescence in an equitable settlement” from a stipulation that “has been merged into the judgment and decree”); - 22 (Minn. 1997) (noting that stipulations are “accorded the sanctity of binding contracts” and “cannot be repudiated or withdrawn from [by] one party without the consent of the other, except by leave of the court for cause shown,” but that “upon entry of a judgment and decree based on a stipulation
- In re the Marriage of: Michelle Beth Kremer v. Robbie Michael Kremer Minn. Ct. App. 2024
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In re the Marriage of: Michelle Beth Kremer v. Robbie Michael Kremer
Minn. Ct. App. 2024
2 (2022) (setting forth limited grounds for reopening a judgment and decree); (“The sole relief from the judgment and decree lies in meeting the requirements of Minn. Stat. § 518.145, subd.
- In the Matter of the Welfare of the Child of: D. J. T. and N. L. T., Parents Minn. Ct. App. 2023
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In the Matter of the Welfare of the Child of: D. J. T. and N. L. T., Parents
Minn. Ct. App. 2023
Whether a signed agreement, later used as the basis for a district court’s final order, is properly a subject of a
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In re the Marriage of:
Minn. Ct. App. 2023
DECISION “Courts favor stipulations in dissolution cases as a means of simplifying and expediting litigation, and to bring resolution to what frequently has become an acrimonious relationship between the parties.” .
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In re the Marriage of: Amanda Leigh Davis Floyd, petitioner, Appellant,
Minn. Ct. App. 2023
-22 (Minn. 1997) (holding that “when a judgment and decree is entered based upon a stipulation, we hold that the 10 stipulation is merged into the judgment and decree and the stipulation cannot thereafter be the target of attack by a party seeking relief from the judgment and decree”); see also Toughill v. T
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In re the Marriage of: Christine Marie Salvosa, petitioner, Appellant,
Minn. Ct. App. 2023
21, 2001); d 519, 522 (Minn. 1997).
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A21-1725
Minn. Ct. App. 2023
2.” d 519, 522 (Minn. 1997); (quoting this aspect of Shirk).
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In re the Marriage of:
Minn. Ct. App. 2023
2.” see Pooley v. Pooley , (quoting this aspect of Shirk).
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In re the Marriage of:
Minn. 2022
ANALYSIS Marriage-dissolution stipulations are a judicially favored means of simplifying and expediting dissolution litigation and are “accorded the sanctity of binding contracts.”
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In re the Marriage of:
Minn. Ct. App. 2022
(stating that “[t]he sole relief from the judgment and decree lies in meeting the requirements of Minn. Stat. § 518.145, subd.
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In re the Marriage of: Kristin Grace Logdahl, petitioner, Respondent,
Minn. Ct. App. 2022
2(2) (2020), the district court may grant a party’s timely motion to reopen a judgment and decree based on “newly discovered evidence which by due diligence could not have been discovered in time to move for a new trial under the Rules of Civil Procedure, rule 59.03.”2 Section 518.145, subdivision 2, provides the “sole relief from the judgment and decree.”
- In re the Matter of: Minn. Ct. App. 2022
- In re the Marriage of: Robert H. Brandtjen, petitioner, Appellant, Minn. Ct. App. 2021
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In re the Marriage of: Linsey Lee Milbrandt, petitioner, Respondent,
Minn. Ct. App. 2021
“Courts favor stipulations in dissolution cases as a me ans of simplifying and expediting litigation, and to bring resolution to what frequently has become an acrimonious relationship between the parties.”
- In re the Marriage of: Bobbi Jean Suhonen, n/k/a Bobbi Jean Lindsay, petitioner, Appellant, Minn. Ct. App. 2021
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In re the Marriage of: Brenda Anne Kiberu-Kalema, n/k/a/ Brenda Anne Kiberu, petitioner, Respondent,
Minn. Ct. App. 2021
Shirk v. Shirk , (citing Minn. Stat. § 518.145, subd.
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In re the Marriage of: Jeffrey Scott Jovaag, petitioner, Appellant,
Minn. Ct. App. 2021
Although courts favor stipulated agreements in dissolution cases, the district court may refuse to accept all or some terms of a stipulated agreement, n.1 (Minn. App. 2000).
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In re the Matter of: Brooks J. Waldron, petitioner, Respondent,
Minn. Ct. App. 2021
As a result, the stipulation became part of the order, and “cannot thereafter be the target of attack by a party seeking relief.” Shirk v. Shirk
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In re the Marriage of: Katherine Theresa Blair, petitioner, Appellant,
Minn. Ct. App. 2021
We are mindful that “[c]ourts favor stipulations in dissolution cases as a means of simplifying and expediting litigation, and to bring resolution to what frequently has become an acrimonious relationship between the parties.”
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In re the Marriage of: Vicki Collette Sandberg, petitioner, Respondent,
Minn. Ct. App. 2021
“First, the party can seek to withdraw from or vacate the stipulation upon which the proposed judgment is based.” Clark v. Clark , ; see Shirk v. Shirk , -22 (Minn. 1997) (addressing a party’s ability to withdraw from a stipulation); (same) .
- In re the Marriage of: Oliver Wilfred Cass, petitioner, Respondent, Minn. Ct. App. 2021
- In re the Marriage of: Kevin James Stanton, petitioner, Appellant, Minn. Ct. App. 2021
- In re the Marriage of: Minn. Ct. App. 2020
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In the Matter of the Civil Commitment of: William Lee Erickson.
Minn. Ct. App. 2020
“Stipulations are therefore accorded the sanctity of binding contracts.”
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In re the Marriage of: Thomas W. Krabbenhoft, petitioner, Respondent
Minn. Ct. App. 2020
(“The sole relief from the judgment and decree lies in meeting th e requirements of Minn. Stat. § 518.145, subd.
- In re the Marriage of: Minn. Ct. App. 2019
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In re the Matter of: David Allen Engh, petitioner, Respondent,
Minn. Ct. App. 2019
The supreme court calls this difference between the statute and the rule “significant[].” n.3 (Minn. 1997).
- In re the Marriage of: Denise Marie Kienholz, petitioner, Respondent, Minn. Ct. App. 2019
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In the Matter of the Civil Commitment of: Edward Eugene Dooley.
Minn. Ct. App. 2019
“Stipulations are therefore accorded the sanctity of binding contracts.”