Cited by
Opinions in Minnesota that cite Putz v. Putz, 645 N.W.2d 343.
- In re the Marriage of: Abdihafid Hariri Hassan Yusuf, petitioner, Appellant, Minn. Ct. App. 2026
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In re the Marriage of:
Minn. Ct. App. 2026
Appellate courts “presume that the Legislature does not intend to abrogate the common law unless it does so by express wording or necessary implication.” (quotation omitted); (declining to view legislative silence as overruling similar common-law requirement in child- support context).
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In the Marriage of:
Minn. Ct. App. 2026
A district court has “broad discretion in ordering modifications to child support orders.”
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In re the Final NPDES/SDS Permit for 3M Cottage Grove Center.
Minn. Ct. App. 2026
But this rule is not “ironclad.”
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In re the Marriage of:
Minn. Ct. App. 2026
We acknowledge that the Thiele rule is not “ironclad.” see also Minn. R. Civ.
- In re the Marriage of: Minn. Ct. App. 2026
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
While appellate courts generally will not consider issues not raised below, this rule is not “ironclad.”
- In the Matter of the Welfare of the Child of: B. L. and B. T., Parents., A25-0623, Court … Minn. Ct. App. 2025
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In the Matter of the Welfare of the Child of: B. L. and B. T., Parents., A25-0623, Court …
Minn. Ct. App. 2025
“This is not, however, an ironclad rule.” d 343, 350 (Minn. 2002) (quotation omitted); see, e.g., Minn. R. Civ.
- County of Dakota, ex rel., Michelle Marie Hinz v. Bryan Arthur ... Minn. Ct. App. 2025
- County of Dakota, ex rel., Michelle Marie Hinz v. Bryan Arthur ... Minn. Ct. App. 2025
- In re the Matter of: Minn. Ct. App. 2025
- Leslie E. Sheehy Lee, Appellant, vs. Travis W. Kalis, Respondent, County of Le Sueur, Respondent Minn. 2025
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Leslie E. Sheehy Lee, Appellant, vs. Travis W. Kalis, Respondent, County of Le Sueur, Respondent
Minn. 2025
(noting the “strong state policy of assuring 15 that children have the adequate and timely economic support of their parents” (citation omitted) (internal quotation marks omitted)).
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Brian’s Lawn & Landscaping, Inc. dba Rock Hard Landscape Supply, Respondent,
Minn. Ct. App. 2025
First, appellants argue that the rule that we will not consider arguments raised for the first time on appeal is not “ironclad.”
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In re the Marriage of:
Minn. Ct. App. 2024
–54 (Minn. 2002) ( for its statement that the supreme court “cannot stress enough the importance of having findings of fact that demonstrate the [district] court actually did take all relevant factors into consideration” and holding that, “[b]ecau
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In re the Marriage of:
Minn. Ct. App. 2024
See Putz v. Putz , (concluding that the child-support magistrate abused his discretion by failing to impute income ); (noting that the district court did not abuse its discretion by imputing income in maintenance context).
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American Academy of Traditional Chinese Medicine, Inc., et al., Respondents,
Minn. Ct. App. 2024
Miller, d at 653 (considering an issue not decided below when it was briefed by the parties and involved a question of law and there was no prejudice); d 343, 350 (Minn. 2002) (considering an issue not raised below and noting that neither party “was represented by counsel” at the relevant hearing).
- In the Matter of the Welfare of the Children of: D. L. W., Legal Custodian Minn. Ct. App. 2023
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In the Matter of the Welfare of the Children of: D. L. W., Legal Custodian
Minn. Ct. App. 2023
But this rule is not “ironclad.”
- Jacqueline Blakey, Jerry Blakey v. Javonda Jones, Gina Alexander, ... Minn. 2023
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Jacqueline Blakey, Jerry Blakey v. Javonda Jones, Gina Alexander, ...
Minn. 2023
This rule, however, is not ironclad, and we have “the authority to take any action ‘as the interest of justice may require.’ ” (quoting Minn. R. Civ.
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State of Minnesota, County of St Louis, Petitioner,
Minn. Ct. App. 2023
-54 (Minn. 2002) (reversing and remanding for a CSM to reconsider child support and “stress[ing] .
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In re the Marriage of:
Minn. Ct. App. 2023
(explaining that appellate courts generally decline to address issues raised for the first time on appeal); (citing Thiele but explaining that appellate courts may consider an issue raised for the first time on appeal in the interest of justice); see also Minn. R. Civ.
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In the Matter of: Eden Tesfaye.
Minn. Ct. App. 2022
But this rule is not “ironclad,” (quotation omitted), and we may address new issues on appeal “as the interest of justice may require,” Minn. R. Civ.
- In re the Marriage of: Holly Joy Klick, petitioner, Appellant, Minn. Ct. App. 2022
- Mower County Health and Human Services, Petitioner, Minn. Ct. App. 2021
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In re the Marriage of:
Minn. Ct. App. 2021
(noting “the child’s paramount right to support and the public protec tion of the child’s best interests”); (no ting strong state policy of assuring that children have adequate and timely economic support of their parents).
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County of Dakota, ex rel., Michelle Marie Hinz, petitioner, Respondent,
Minn. Ct. App. 2021
Ludwigson, d at 445 -46 (citations omitted); d 343, 348 (Minn. 2002) (where there had been no district court review of a CSM’s order, the supreme court applied the abuse -of-discretion standard after noting that this cou rt “applied the abuse of discretion standard and the parties agree that it is the appropriate standard of review”).
- In re the Marriage of: Kevin James Stanton, petitioner, Appellant, Minn. Ct. App. 2021
- In re the Marriage of: John Sterling Ross, petitioner, Appellant, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
Although questions that a district court did not decide are generally not amenable to appellate review, this rule is not “ironclad.” Putz v. Putz , see Minn. R. Crim.
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In the Matter of the Civil Commitment of: Brian James Turner.
Minn. Ct. App. 2020
But this rule is not “ironclad.” d 343, 350 (Minn. 2002).
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Jennifer Schroeder, et al., Respondents,
Minn. Ct. App. 2020
See Putz v. Putz , (stating that the rule precluding consideration of issues not raised to the district court is not ironclad); see also Minn. R. Civ.
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In re the Marriage of: Jane Ann Holm, petitioner, Respondent,
Minn. Ct. App. 2020
App. P. 103.04 , particularly with respect to pro se litigants
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Nancy Leppink, Commissioner of the Minnesota Department of Labor and Industry, et al., Respondents,
Minn. Ct. App. 2020
Moreover, although not “ironclad,” Putz v. Putz , (quotation omitted), the principle is regularly observed by both the supreme court and this court.
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In re the Marriage of: Nathan Winesett, petitioner, Appellant,
Minn. Ct. App. 2020
Father forfeited any objection to conducting the October 26 hearing without prior settlement efforts, see Putz v. Putz , and the district court did not abuse its discretion by giving mother a n opportunity to resp ond to father’s untimely motion to increase spousal maintenance, see Minn. R. Gen.
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In re the Marriage of:
Minn. Ct. App. 2020
(child support); d 921, 923 (Minn. App. 1992) (spousal maintenance) .
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In re the Marriage of:
Minn. Ct. App. 2020
“[A] district court enjoys broad discretion in ordering modifications to child support orders” provided that it exercises that discretion “within the limits set by the legislature.” Putz v. Putz
- Michelle L. MacDonald, et al., Appellants, Minn. Ct. App. 2020
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In re the Marriage of: Zondra A. Thompson, petitioner, Respondent,
Minn. Ct. App. 2020
District courts must “make thorough and accurate findings of fact regarding the obligor’s monthly net income.”
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In re the Marriage of: Michael James Pudlick, petitioner, Appellant,
Minn. Ct. App. 2019
While the district court has broad discretion in ordering a modification of child support, it abuses its discretion when it acts outside the statutory limits set by the legislature or resolves the matter “by reaching a clearly erroneous conclusion that is against logic and the facts on record.”
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Shane Foss, Appellant,
Minn. Ct. App. 2019
d 343, 347 (Minn. 2002).
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In re the Marriage of: Amy Alyssa Post, petitioner, Respondent,
Minn. Ct. App. 2019
However, 10 the rule that issues raised for the first time on appeal will not be addressed is not “ironclad.” Putz v. Putz , (quotation omitted); see Minn. R. Civ.
- Miller v. Soo Line R.R. Co. 925 N.W.2d 642 Minn. Ct. App. 2019
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Miller v. Soo Line R.R. Co.
925 N.W.2d 642
Minn. Ct. App. 2019
Putz v. Putz , , 350 (Minn. 2002) ; see also Minn. R. Civ.
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In the Matter of the Welfare of the Children of: S.S.H. and B.W.R., Parents
Minn. Ct. App. 2018
App. P. 103.04 (providing that an appellate court may review any matter as the interests of justice may require); (stating appellate courts can take “any action as the interests of justice may require”) (quotation omitted).
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In re the Marriage of: Terry Anne Boggs, petitioner, Appellant,
Minn. Ct. App. 2018
A factual fi nding is clearly erroneous only if it is “against logic and the facts on record,” Putz v. Putz , leaving the 4 reviewing court with “the definite and firm conviction that a mistak e has been made.” (quotation omitted).
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David Forster, et al., Respondents,
Minn. Ct. App. 2017
11 Nonetheless, the rule that issues raised for the first time on appeal will not be addressed is not “ironclad.” see Minn. R. Civ.
- County of Anoka, petitioner, Respondent, Minn. Ct. App. 2017