Cited by

(“[T]here is scant if any room for this court to question a district court’s balancing of best-interests considerations.” 2 Mother also argues that the district court later erred at trial because it did not allow “a w

see also In 4 re Welfare of C.F.N., (“[T]here is scant if any room for this court to question a district court’s balancing of best-interests considerations.” (quotation omitted)), rev. denied (Minn. Mar.

(holding that because a parent’s child-support obligation depends upon the division of parenting time, the amount of child support should be determined after parenting-time issues are resolved).

4 We reach this conclusion, in part, because the caselaw cited by mother uses the term “substantial” in the context of a “restriction.” which discusses the standard governing a “substantial alteration of visitation rights amounting to a ‘restriction,’ of visitation” which makes a related statement.

Although we observed in Dahl that “[a] restriction occurs when a change to parenting time is ‘substantial[,]’” d at 123–24 (), and that “[m]odifications are ‘less substantial changes’ in parenting time[,]” id.

(concluding that reduction by one-half was substantial); -86 (Minn. App. 1984) (concluding that reduction from 14 weeks to five and one-half weeks (i.e., 61 percent) was restriction), rev. 9 denied (Minn. June 12, 1984), with Suleski, d at 337 (con

(reversing, in part, because the district court “significantly” reduced mother’s parenting time without an evidentiary hearing).

In addition, the best interests standard applies to modifications of parenting time that do not constitute a “restriction,” including modifications that reduce one parent’s parenting time to “an amount that is between 45.1 to 54.9 percent parenting time,” Minn. Stat. § 518.175, subd.

Nice-Petersen v. Nice-Petersen , 72 (Minn. 1981)

(citation omitted); (noting that the same requirements apply to motions to modify legal and physical custody).

P. 63.03 provides that a party must file its no tice to remove a judge before the judge first presides in an action, unless the party makes an affirmative showing of the judge’s prejudice or implied or actual bias.” Matson v. Matson

P. 63.03 provides that a party must file its notice to remove a judge be fore the judge first presides in an action, unless the party makes an affirmative showing of the judge’s prejudice or implied or actual bias .” Matson v. Matson , (emphasis added).3 In an affidavit attached to the notice of motion to disqualify, husband complained of the district court’s decisions against him on the issues of bifurcation and the validity of a postnuptial agreement.

d 462, 469 (Minn. App. 2002).

review denied (Minn. Oct.

The district court changed the schedule to the following: 8 the 7% change in Suleski which we held to be insubstantial, d at 337, but less than the 50% reduction found to constitute a d 462, 468 (Minn. App. 2002) .

Father argues, however, that a district court must find a change in circumstances before modifying a parenting-time arrangement.

(stating insubstantial modification does not require evidentiary hearing and is appropriate if modification serves child’s best interests), review denied (Minn. Oct.

The district court must conduct such a hearing only if there is a substantial modification or adjustment of parenting time, which “depends on whether parenting time was restricted.”

rt erred in denying his motion for sole physical custody, asserting that “if the endangerment standard is met to modify legal custody, it must also have been met to modify physical custody.” In support of his argument, Kaminski cites Matson v. Matson, which states that the standards contained in Minn. Stat. § 518.18(d) “apply to the modification of legal custody, as well as physical custody.”