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Following final disposition of the parties’ marital property in a dissolution judgment, a district court has discretion to issue orders to clarify, implement, or enforce the terms of the judgment, but it generally may not modify the property settlement, d 272, 275 (Minn. App. 1999).

1a.10 These fees may be warranted, for example, if a party takes positions that are “duplicitous and disingenuous.”

An award of conduct-based attorney fees is appropriate when a party takes positions that are “duplicitous and disingenuous and have had the effect of further delaying distribution, lengthening [the] litigation, and increasing the expense of [the] proceedings.” Redmond v. Redmond

An award of conduct-based attorney fees is appropriate if a party takes positions that are “duplicitous and disingenuous and have had the effect of further delaying distribution, lengthening litigation, and increasing the expense of these proceedings.”

see also Minn. Stat. § 518.145 (2022) (providing for reopening of a dissolution decree for specified reasons within a year of entry of the judgment and decree).

We agree with husband.1 While a district court may not modify a final property division except in limited circumstances not applicable here, “it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” see Minn. Stat. § 518.145, subd.

lengthening [the] 5 litigation, and increasing the expense of [the] proceedings.” Redmond v. Redmond

lengthening [the] litigation, and increasing the expense of [the] proceedings.”

He argues that his substantive rights were affected “because the terms of the decree are property and property awards are final.” “While a [district] court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.” Redmond v. Redmond

See Bakken v. Helgeson , (holding that whether a transaction constitutes a “sale” for purpose of triggering a duty to pay in a dissolution judgment is a question of fact) (); see also Ministers Life Cas.

(affirming award of conduct -based attorney fees based in part on party’s “noncooperation and obstinate position”).

A district court “may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.”

“‘While a [district] court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.’” (alteration in original) ().

App. P. 138 where an appellant’s positions have been “duplicitous and disingenuous and have had the effect of further delaying distribution, lengthening this litigation, and increasing the expense of these proceedings.”

“While a [district] court may not modify a final property division, it may issue orders to implement, enforce, or clarify the provisions of a decree, so long as it does not change the parties’ substantive rights.”

(reviewing decision that transaction was sale as finding of fact subject to reversal only if clearly erroneous).

Cf. Gales, d at 423 (denying attorney fees on appeal because appellant’s arguments in the appeal were “neither frivolous nor asserted in bad faith”); (awarding conduct-based attorney fees on appeal because positions taken by appellant were “duplicitous and disingenuous and have had the effect of further delaying distribution, lengthening this litigation and increasing the expense of these proceedings”)..