Cited by
Opinions in Minnesota that cite Marriage of Geske v. Marcolina, 624 N.W.2d 813.
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In re the Marriage of: John Alex Walker, petitioner, Appellant,
Minn. Ct. App. 2021
“Conclusory findings on the statutory factors do not adequately support a fee award.”
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In re the Marriage of: Rupam Sinha, petitioner, Respondent,
Minn. Ct. App. 2021
Geske v. Marcolina , -19 (Minn. App. 2001).
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Trung Thien Do, Respondent,
Minn. Ct. App. 2021
“While bad faith could unnecessarily increase the length or expense of a proceeding, it is not required for an award of conduct -based attorney fees.” –19 (Minn. App. 2001).
- In re the Marriage of: Ajay K. Israni, petitioner, Respondent, Minn. Ct. App. 2021
- In re the Marriage of: Dia Eldin Jubara, petitioner, Respondent, Minn. Ct. App. 2021
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In re the Marriage of:
Minn. Ct. App. 2020
n.2 (Minn. App. 2001) (addressing viability of pre-amendment caselaw).
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In re the Marriage of: Kimberly JoAnn Wauzynski, n/k/a/ Kimberly JoAnn Denne, petitioner, Appellant,
Minn. Ct. App. 2020
In general, “[c]onclusory findings on the statutory factors do not adequately support a fee award.” Geske v. Marcolina
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In re the Marriage of: Amanda Jo Briggs, petitioner, Respondent,
Minn. Ct. App. 2020
bility to pay the attorneys’ fees Wife incurred, and that [Wife] does not—particularly in light of the fact that she has no real retirement saving and the Court is imputing income to her at a time she is not working a meaningful number of hours.” We deem these findings conclusory, and “[c] onclusory findings on the statutory factors do not adequately support a fee award.” review denied (Aug.
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In re the Marriage of: John Gordon Lewis, petitioner, Respondent,
Minn. Ct. App. 2020
See, e.g., Szarzynski v. Szarzynski , -96 (Minn. App. 2007); Geske v. Marcolina , -19 (Minn. App. 2001).
- In re the Marriage of: Dia Eldin Jubara, petitioner, Respondent, Minn. Ct. App. 2020
- Erin Elisabeth Dancour, n/k/a Erin Elisabeth Meyers, Appellant, Minn. Ct. App. 2020
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In re the Marriage of: Jane Swenson Amdal, petitioner, Respondent,
Minn. Ct. App. 2020
See Geske v. Marcolina , review denied (Minn. Aug.
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In re the Marriage of:
Minn. Ct. App. 2020
A district court may award attorney fees “against a party wh o unreasonably contributes to the length or expense of the proceeding.” (quotation omitted).4 But, generally, “behav ior occurring outside the litigation process” cannot be the basis for such a fee award.
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In re the Marriage of: Adetola Omolola Allen, n/k/a Adetola Omolola Abodunde, petitioner, Appellant,
Minn. Ct. App. 2020
1.” -19 (Minn. App. 2001).
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A19-1182
Minn. Ct. App. 2020
In general, “[c]onclusory findings on the statutory factors do not adequately support a fee award.” d 813, 817 (Minn. App. 2011).
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In re the Custody of: C.A.M., Cody A. Myers, petitioner, Respondent,
Minn. Ct. App. 2020
review denied 3 It appears that mother also requests attorney fees , but her request is not properly before us because she never made a rule 127 motion.
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In re the Marriage of: Nathan Winesett, petitioner, Appellant,
Minn. Ct. App. 2020
(reasoning that a lack of specific findings “is not fatal” to a need-based fee award where review of the order “reasonab ly implies” that the court considered the relevant factor s and the court was familiar with the parties’ circumstances (quotation omitted)).
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In re the Marriage of:
Minn. Ct. App. 2020
” Baertsch v. Baertsch , ().
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In re the Marriage of: Jonathon Henry Ortner, petitioner, Appellant,
Minn. Ct. App. 2020
1.” -19 (Minn. App. 2001).
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In re the Marriage of: Susan Lee Wood, petitioner, Respondent,
Minn. Ct. App. 2019
1.” –19 (Minn. App. 2001).
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In re the Marriage of: Mary Elizabeth Moline, petitioner, Respondent,
Minn. Ct. App. 2019
1 (2018), which allows for need-based fee award s. Geske v. Marcolina
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In re the Marriage of: Aaron Di Luong, petitioner, Appellant,
Minn. Ct. App. 2019
Such attorney fees are generally referred to as “need-based fees,” see, -17 (Minn. App. 2001), and we review an award of need-based attorney fees for an abuse of discretion.
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In re the Marriage of: Kathleen Marie Tiedke, nka Kathleen Marie Freitag, petitioner, Respondent,
Minn. Ct. App. 2019
The attorney fees described in the first sentence of this statute typically are called “need -based fees.” See Geske v. Marcolina , d 813, 816-17 (Minn. App. 2001).
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In re the Marriage of: Sharon Nelson, petitioner, Respondent,
Minn. Ct. App. 2019
The attorney fees described above are typically referred to as “need-based fees.” -17 (Minn. App. 2001).
- In re the Marriage of: David Michael Kedrowski, petitioner, Appellant, Minn. Ct. App. 2019
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In re the Marriage of: Thomas M. Dillahunt, petitioner, Respondent,
Minn. Ct. App. 2019
1.” -19 (Minn. App. 2001).
- In re the Marriage of: Minn. Ct. App. 2019
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In re the Marriage of: Lauri Sue Browning, petitioner, Respondent,
Minn. Ct. App. 2019
See, e.g., Madden, d at 702; Szarzynski v. Szarzynski , -96 (Minn. App. 2007) ; Geske v. Marcolina , 8-19 (Minn. App. 2001).
- A18-1065 Minn. Ct. App. 2019
- In re the Marriage of: Kimberly Kay Seidel, petitioner, Appellant, Minn. Ct. App. 2019
- In re the Marriage of: Beth Ann Bersaw, petitioner, Respondent, Minn. Ct. App. 2019
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In re the Marriage of: Nicole Marie Anne Sanders, petitioner, Appellant,
Minn. Ct. App. 2019
1 (2018); -19 (Minn. App. 2001).
- Madden v. Madden 923 N.W.2d 688 Minn. Ct. App. 2019
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Madden v. Madden
923 N.W.2d 688
Minn. Ct. App. 2019
See Geske v. Marcolina , , 816-17 (Minn. App. 2001).
- In re the Marriage of: Laurie S. Morris Hiniker a/k/a Laurie Suzette Morris, petitioner, Respondent, Minn. Ct. App. 2019
- Muschik v. Conner-Muschik 920 N.W.2d 215 Minn. Ct. App. 2018
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Muschik v. Conner-Muschik
920 N.W.2d 215
Minn. Ct. App. 2018
Geske v. Marcolina , , 816 (Minn. App. 2001).
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In re the Marriage of: Terry Anne Boggs, petitioner, Appellant,
Minn. Ct. App. 2018
See Geske v. Marcolina , -18 (Minn. App. 2001) (addressing need-based attorney’s fees).
- In re the Custody of M. M. L. Minn. Ct. App. 2018
- In re the Marriage of: Sonja Vogen Baertsch, petitioner, Respondent, Minn. Ct. App. 2018
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In the Matter of the Estate of: Prince Rogers Nelson, Decedent.
Minn. Ct. App. 2018
review denied (Minn. Feb.
- Marriage of Mattson v. Mattson 903 N.W.2d 233 Minn. Ct. App. 2017
- Marriage of Mattson v. Mattson 903 N.W.2d 233 Minn. Ct. App. 2017
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In re the Marriage of: Jennifer Kristin Gorney, petitioner, Respondent,
Minn. Ct. App. 2017
1 (2016); see also Geske v. Marcolina
- In re the Marriage of: Robert William Bessenbacher, petitioner, Appellant, Minn. Ct. App. 2017
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In re the Marriage of: Teresa Marie Nordahl, petitioner, Respondent,
Minn. Ct. App. 2017
18, 1999); d 813, 816 n.1 (Minn. App. 2001).
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In re the Marriage of: Donald Wayne Leeke, petitioner, Appellant,
Minn. Ct. App. 2017
Husband notes that “[c]onclusory findings on the statutory factors do not adequately support a fee award.” Geske v. Marcolina
- In re the Marriage of: Cassie Marie Birr, petitioner, Respondent, Minn. Ct. App. 2017
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In re the Marriage of: Michael R. Shreve, petitioner, Appellant,
Minn. Ct. App. 2017
review denied (Minn. Aug.
- In re the Matter of: J. S. S., petitioner, Respondent, Minn. Ct. App. 2017