Cited by

9 In addition, because 9 Additionally, in Tuthill v. Tuthill, we explained that the finding that the movant’s lifestyle had not changed “despite his claims of financial adversity” was sufficient “to indicate that the initial award continues to be fair and reasonable.”

d 230, 232 (Minn. App. 1987) (acknowledging that the district court’s findings lacked detail but reasoning that the husband “ha[d] failed to present a complete picture of his assets and debts making such findings impossible”); ( “On appeal, a party cannot

(ruling, in maintenance -modification context, that movant’s failure to show statutorily required change of circumstances was fatal to motion to modify maintenance, and hence that “it is not necessary for the [district] court to make findings regarding any other factors addressed in the statu

(ruling, in the context of a motion to modify maintenance, that a movant’s failure to show the statutorily required change of circumstances was fatal to the motion, and hence that “it [was] not necessary for the trial court to make findings regarding any other factors addressed in the statut

He cannot complain now that the district court failed to make a more detailed analysis when “he has failed to present a complete picture of his assets and debts .” ; (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

(ruling, in the maintenance- 20 modification context, that the movant’s failure to show the statutorily required change of circumstances was fatal to the motion to modify maintenance, and hence that “it is not necessary for the trial court to make findings regarding any other factors addresse

App. 1987); see also Tuthill v. Tuthill , (holding that a district c ourt may consider a party’s failure to provide financial documentation when determining whether to modify maintenance).

In maintenance-modification proceedings, “particularized findings are necessary to show that relevant statutory factors have been considered.” d 230, 232 (Minn. App. 1987).

(stating that insufficient findings require remand for further findings); (stating that property division does not require detailed findings but findings “suffi cient to allow appellate review”).

(applying predecessor to Minn. Stat. § 518A.39).

(holding that failure to show substantially changed circumstances precludes modification of spousal maintenance, therefore district court need not make findings regarding other statutory factors).

See Tuthill v. Tuthill , 2 6 (Minn. App. 1987).

(“The failure to show such a change [in circumstances] precludes a modification of maintenance obligations under [the spousal-maintenance-modification statute].

In short, husband “failed to present a complete picture of his assets and debts making [specific] findings impossible.”

(“The failure to show [a substantial change in circumstances] precludes a modification of maintenance obligations under Minn. Stat. § 518.64, subd.

“In modification of maintenance obligations, as well as in the initial determination, particularized findings are necessary to show that relevant statutory factors have been considered.”

2 (2016); Bormann v. Bormann , -81 (Minn. App. 2002) (support); (maintenance) (quotation omitted).

2 (2016 ); Tuthill v. Tuthill , see also Kielley v. Kielley , (“Unreasonable and unfair are strong terms which place upon the claimant a burden of proof more than cursory.

d 230, 232 (Minn. App. 1987) (stating, in the context of a maintenance modification motion, that once the district court found a lack of substantially changed circumstances, a failure to make findings on other maintenance factors did not constitute reversible error); (Minn. App

6(e) (stating the district court is not authorized to order the responsible agency to place the child in the moving party’s home unless the district court finds that “the agency has been unreasonable in failing to make the adoptive placement and that the relative or child’s foster parent is the most suitable adoptive home to meet the child’s needs”) (emphasis added); (stating that, when the moving party failed to show a prerequisite for modifying maintenance, the district court did not need to a

(Minn. 2 The 2011 tax return submitted by husband shows his salary as a psychiatrist to be $86,985 and his current wife’s salary to be $114,635.70.

See Loth, 227 Minn. at 392, d at 546; (refusing to remand, in a maintenance-modification proceeding, for findings regarding the amount and duration of a maintenance award when the moving party failed to show the existence of the changed circumstances necessary to modify that award).

(stating that, when the moving party failed to show the substantial change in circumstances required for a modification of maintenance, the district court did not need to make findings on other factors listed in the modification statute).

5 (Minn. App. 1987) (noting that “a remand is not appropriate” when “the findings indicate that the relevant statutory factor[s]” were considered (emphasis added)).

(reciting this rule in maintenance-modification context); (reciting this rule in support-modification context).