Cited by

().5 A district court “shall”6 award attorney fees, costs, and disbursements necessary to carry on or contest marriage dissolution proceedings if it finds: 5 This court has previously concluded that it reviews a district court’s award of need-based attorney fees for an abuse of discretion.

(affirming an award of need-based attorney fees despite a lack of findings when the record 13 showed the judge “was familiar with the history of this case and that, in [awarding the] fees, the judge had access to the [relevant information]”).

(“In cases involving child support obligations, the court plays a unique role in that it sits as a third party, representing all of the citizens of the state of Minnesota to see that children benefit from the income of their parents.”).

“[When] the court is familiar with the history of the case and has access to the parties’ financial information, it may waive the requirements of Rule 119.”

e Lauren did not formally move for attorney fees, “the court found that there was no evidence that any conduct by [Brent] was improper, and [Lauren] failed to establish that she did not have the means to pay her own attorney fees.” Generally, the “standard of review for an appellate court examining an award of attorney fees is whether the district court abused its discretion.” (reviewing a need-based fee award).

In the context of need -based attorney fees, our standard of review “is whether the district court abused its discretion.”

-26 (Minn. 1999); (stating that “[o]n appeal, a party cannot complain about a district court’s failure to rule in her favor when one of the reasons it did not do so is because that party failed to provide the district court with the evidence

(“A trial court’s determination of the amount and duration of spousal maintenance is final unless the court abused the discretion accorded to it.” ()); (“The standard of review for an appellate court examining an award of attorney fees is whether the district 2 Because we reverse the district court’s decision regarding its classification of the 5.78- acre property as nonmarital, we do not reach Beth Ann’s alternative arguments that the district

P. 52.01; n.3 (Minn. 1999) (citing rule 52.01 in a support-modification appeal).

d 47, 51 (Minn. 1984); Szarzynski, d at 295.

We review a district court’s factual findings for clear error, questions of law de novo; and the ultimate decision of whether to modify child support for an abuse of discretion, 2

ure to make specific findings on these statutory factors is “not fatal to an award where review of the order ‘reasonably implies’ that the district court considered the relevant factors and where the district court ‘was familiar with the history of the case’ and ‘had access to the parties’ financial records.’” (-26 (Minn. 1999)).

(spousal maintenance); Lee v. Lee , (division of marital property); (attorney fees).

(“A district court has discretion to strictly enforce or to waive the requirements of rule 119 when considering a motion for attorney fees .”); (affirming award of attorney fees despite party’s failure to file required affidavits).

d 814, 825 (Minn. 1999).

Id.; (holding that district court could waive requirements of rule 119.02 in part because the rule does not limit the court’s discretion).

d 47, 51 (Minn. 1984); Szarzynski, d at 295.

We review a district court’s factual findings for clear error, questions of law de novo, and the ultimate decision to modify child support for an abuse of discretion

see Minn. Stat. § 518.14, subd.

see Minn. Stat. § 518.14, subd.

“The standard of review for an appellate court examining an award of attorney fees is whether the district court abused its discretion.”

A CSM is afforded broad discretion in making child-support determinations, and we defer to the CSM’s credibility determinations