Cited by
Opinions in Minnesota that cite Marriage of Duffney v. Duffney, 625 N.W.2d 839.
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In the Marriage of:
Minn. Ct. App. 2025
(failing to include $25 per month of income was de minimis error); Risk ex rel.
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In re the Marriage of:
Minn. Ct. App. 2024
16, 2010); (holding that understating father’s monthly income by $20 to $25 was “de minimis and does not warrant a remand”).
- In re the Marriage of: Daniela Tate v. Daniel Lee Tate Minn. Ct. App. 2024
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In re the Marriage of: Daniela Tate v. Daniel Lee Tate
Minn. Ct. App. 2024
When the district court erroneously calculates a party’s income, this court can decline to remand if the error is “de minimis.”
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In re the Marriage of: Pamela Jo Pemberton, petitioner, Respondent,
Minn. Ct. App. 2023
(concluding that a de minimis error does not warrant a remand).
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In re the Marriage of: John Alex Walker, petitioner, Appellant,
Minn. Ct. App. 2021
See, (district court’s failure to include $25 per month of income); Risk ex rel.
- In re the Marriage of: Martin Sean Schmidt, petitioner, Respondent, vs. Julie Ann Schmidt, Appellant. Minn. Ct. App. 2021
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In re the Marriage of: Rupam Sinha, petitioner, Respondent,
Minn. Ct. App. 2021
16, 2010); Duffney v. Duffney , (holding that the district court’s failure to include $20 to $25 in the calculation of a party’s monthly income was “de minimis and does not warrant a remand”).
- In re the Marriage of: Minn. Ct. App. 2020
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In the Matter of: Tamara Lynn Kriesel, petitioner, Respondent,
Minn. Ct. App. 2019
See Duffney v. Duffney , (declining to remand for de minimis error) .
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In re the Matter of: Peter H. Stier, petitioner, Appellant,
Minn. Ct. App. 2017
See, e.g., Hesse, d at 105; d 839, 843 (Minn. App. 2001) ; Wibbens v. Wibbens , see also Risk ex rel.
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John Frederick Stolte, petitioner, Respondent,
Minn. Ct. App. 2017
See Minn. Stat. § 518A.29(a) (2016) (defining “gross income” for purposes of spousal maintenance to mean “periodic payment to an individual”); -43 (Minn. App. 2001) (concluding that proceeds from sale of asset was not income for purposes of child support).
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In re the Marriage of: Joanna Brooks Benson, f/k/a Joanna Lee Brooks, petitioner, Appellant,
Minn. Ct. App. 2017
-43 (Minn. App. 2001) (concluding that proceeds of sale of timber from obligor’s land was not income for purposes of child support).
- In re the Marriage of: William David Wilder v. Michelle R. Wilder Minn. Ct. App. 2016
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In re the Marriage of: William David Wilder v. Michelle R. Wilder
Minn. Ct. App. 2016
(“Generally, if a payment is periodic, it is income.”); (noting that dependable sources of income may properly be included in an income calculation).
- In re the Marriage of: Kathryn R. Rauworth, n/k/a Kathryn R. Kendall v. Barry L. Rauworth Minn. Ct. App. 2015
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In re the Marriage of: Kathryn R. Rauworth, n/k/a Kathryn R. Kendall v. Barry L. Rauworth
Minn. Ct. App. 2015
13 Generally, gross income “includes any form of periodic payment to an individual.” Minn. Stat. § 518A.29(a) (2014).3 The cyclic or periodic nature of the receipt of funds is critical to classifying that receipt of funds as “income.” d 839, 843 (Minn. App. 2001).
- Hubbard County Health & Human Services v. Zacher 742 N.W.2d 223 Minn. Ct. App. 2007
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Hubbard County Health & Human Services v. Zacher
742 N.W.2d 223
Minn. Ct. App. 2007
(“Generally, if a payment is periodic it is income.”).
- Marriage of Schlichting v. Paulus 632 N.W.2d 790 Minn. Ct. App. 2001
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Marriage of Schlichting v. Paulus
632 N.W.2d 790
Minn. Ct. App. 2001
at 821 n. 19; , 842 n. 1 (Minn.App.2001) (declining to comment on the propriety of the assumption that the Hortis/Valento formula is proper in a case of joint physical custody).
- Marriage of Davis v. Davis 631 N.W.2d 822 Minn. Ct. App. 2001
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Marriage of Davis v. Davis
631 N.W.2d 822
Minn. Ct. App. 2001
See, , 842 n. 1 (Minn.App.2001) (declining to comment on the propriety of the assumption that the Hortis/Valento formula is proper in a joint physical custody case); (stating appellate courts generally address only issues presented to and decided by the district co