Cited by

A district court’s or magistrate’s failure to make findings on statutorily required factors in its modification analysis requires remand for additional findings, “[e]ven if a modification were justified.”

Commitment of Spicer, (reversing because the district court’s findings were “insufficient to enable an appellate court to determine whether the trial court properly considered the [statutory] requirements”).

r include a provision allowing law enforcement to facilitate parenting time if needed , and (5) that mother cooperate in obtaining a passport for the child.6 “Effective appellate review of the exercise of [a district court’s] discretion is possible only when the trial court has issued sufficiently detailed findings of fact to demonstrate its consideration of all factors.”

.” (reversing the district court’s spousal-maintenance decision based on insufficient findings and remanding the matter to the district court “for additional findings”).

To support th is argument, father emphasizes that the district court expressly “decline[d]” to make detailed findings in its order “on each and every factor commonly referred to as the ‘best interest[s] factors.’” for the proposition that “[e]ffective appellate review .

instructed the district courts to “ide ntify both [their] decision (e.g., spousal maintenance, child support, parenting time) as well as the underlying reason(s) for that decision (i.e., findings showing why the amount of maintenance, child support or parenting time is appropriate in the particular case).” - 18 (Minn. App. 2012) ( ).

15 “Where the trial court has broad discretion, the Minnesota Supreme Court has demonstrated persistence in demanding findings to explain the trial court’s exercise of discretion.” In re Amitad, Inc., (remanding for additional findings where district court’s findings were insufficient to enable an appellate court to determine whether district court properly considered statutory requirements).

(stating that “it is not the role of appellate courts to scour the record to determine if sufficient evidence exists to support the district court’s” exercise of its discretion); (observing that sufficiently detailed findings of fact assist appellate courts in effectively reviewing decisions subject to an abuse of discretion review).

(holding that failing to make findings on relevant statutory factors requires remand to the district court) ; accord In re Welfare of the Child of D.L.D.

Findings and conclusions must be sufficient to permit meaningful appellate review, see Stich v. Stich , and clear findings and conclusions weighing the Shetsky factors aid appellate review.

See Stich v. Stich , (holding a district court’s findings insufficient where the district court made findings concerning the parties’ incomes, but not concerning their separate expenses).3 3 We do note, but do not rely on as precedent, our opinion in Hammond v. Buchanan

4 Stich v. Stich , d 52, 53 (Mi nn.

A district court’s assessment of a party’s reasonable expenses is a factual finding, which we will not set aside absent clear error, Minn. R. Civ.

But appellate review is possible only when the district court makes findings that are sufficiently detailed to show its consideration of “all factors relevant to an award.” (“ Effective appellate review of an award of maintenance is possible only when the [district] court has issued sufficiently detailed 1 We note that “permanent maintenance” is a “term

d 52, 53 (Minn. 1989) (noting that the district court’s findings were insufficient to enable an appellate court to determine whether the district court had properly considered statutory requirements for awarding spousal maintenance); Dougherty v. Dougherty , d 193, 194 -95 (Minn. App. 1989) (noting that a dist

(reversing and remanding for further findings); (stating general rule that district court’s failure to make findings on relevant statutory factors requires remand).

Conducting effective appellate review of a district court’s exercise of its discretion in awarding spousal maintenance “is possible only when the [district] court has issued sufficiently detailed findings of fact to demonstrate its consideration of all factors relevant to an award of permanent spousal maintenance.”

(stating, in a dispute over an award of spousal maintenance, that “[e]ffective appellate review of the [district court’s] discretion is possible 5 only when the [district] court has issued sufficiently detailed findings of fact to demonstrate its co

(reversing and remanding a maintenance award because it lacked adequate supporting findings of fact); (stating that without specific findings as to a recipient’s reasonable expenses, “it is impossible to review whether [mother] meets the s

1, 2010); (stating that provide that the obligation was to end 72 months from the date of entry of judgment, i.e., beyond March 2015.

See In re Amitad, Inc., (“Where the [district] court has broad discretion, the Minnesota Supreme Court has demonstrated persistence in demanding findings to explain the [district] court’s exercise of discretion.”); (remanding for further findings because “[e]ffective appellate review .

(stating, in a dispute over an award of spousal maintenance, that “[e]ffective appellate review of the [district court’s] discretion is possible only when the [district] court has issued sufficiently detailed findings of fact to demonstrate its consideration of [all relevant factors]”); Wallin v. W

at 217-18 ( (stating, in spousal-maintenance context, that “[e]ffective appellate review of the exercise of [the district court’s] discretion is possible only when the [district] court has issued sufficiently detailed findings of fact to demonstrate its consideration [of all relevant factors]”); Wallin v. Wall