Cited by
Opinions in Minnesota that cite Dabill v. Dabill, 514 N.W.2d 590.
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In Re the Custody of J. K. S.
Minn. Ct. App. 2025
In Szarzynski v. Szarzynski, for example, we held that “lack of endangerment is fatal to a motion to modify custody.” (describing endangerment as a “threshold” for modifying custody).
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A24-0752
Minn. Ct. App. 2024
does not establish danger to the welfare of children without evidence of actual adverse effects.” Dabill v. Dabill , -96 (Minn. App. 1994).
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In re the Marriage of:
Minn. Ct. App. 2024
See Harkema, d at 14; Taflin, d at 321 (concluding district court abused its discretion by denying motion to modify custody without evidentiary hearing when father’s affidavit made prima facie showing of endangerment); (reversing district court’s child-custody modification when evidence did not show endangerment).
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In re the Marriage of: Catrina M. Rued, petitioner, Respondent,
Minn. Ct. App. 2023
central and concerning in its review” and that “multiple qualified professionals and the Court have expressed concern over source monitoring.” The district court took judicial notice of factual findings from its October 2020 custody order (first custody order) that father and grandparents have created a source monitoring problem for the child “due to the 7 stands for the proposition that a finding of endangerment requires “actual adverse effects to the child as a result of the parenting time.” B
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In re the Marriage of: Melissa Ann Kuchera, petitioner, Appellant,
Minn. Ct. App. 2022
” - 96 (Minn. App. 1994) .
- Distinguished A21-1064 Minn. Ct. App. 2022
- In re the Matter of: Calvin James Omtvedt v. Amanda Marie Jansen Minn. Ct. App. 2015
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In re the Matter of: Calvin James Omtvedt v. Amanda Marie Jansen
Minn. Ct. App. 2015
This court has stated that “to establish danger to a child’s welfare, a parent’s conduct must be shown to result in an actual adverse effect on the child.” –96 (Minn. App. 1994) (“Normally, given the statutory requirement for proof of endangerment as a condition for a custody modification, the conduct or circumstance of a parent, including visitation interference, does not establish danger to the welfare of children without evidence of actual adverse effects.”).
- In re the Marriage of: Thomas M. Dillahunt v. Tami L. Dillahunt, n/k/a Tami L. Mitchell Minn. Ct. App. 2014
- In re the Marriage of: Thomas M. Dillahunt v. Tami L. Dillahunt, n/k/a Tami L. Mitchell Minn. Ct. App. 2014
- In re the Marriage of: Jonathan Conneely v. Hannah Stancek, f/k/a Hannah Conneely Minn. Ct. App. 2014
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In re the Marriage of: Jonathan Conneely v. Hannah Stancek, f/k/a Hannah Conneely
Minn. Ct. App. 2014
to support her contention that establishing endangerment requires a showing that a custodial parent’s conduct “must be shown to have an actual, adverse effect on the child” and that “[u]nwarranted denial of or interference with visitation alone is not enough to modify custody.” Stancek reads Dab
- Szarzynski v. Szarzynski 732 N.W.2d 285 Minn. Ct. App. 2007
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Szarzynski v. Szarzynski
732 N.W.2d 285
Minn. Ct. App. 2007
(describing endangerment as “threshold” for modifying custody).
- Dalbec v. W.P.W. 653 N.W.2d 804 Minn. Ct. App. 2002
- In Re Weber 653 N.W.2d 804 Minn. Ct. App. 2002
- In Re Weber 653 N.W.2d 804 Minn. Ct. App. 2002
- Dalbec v. W.P.W. 653 N.W.2d 804 Minn. Ct. App. 2002
- Rutz v. Rutz 644 N.W.2d 489 Minn. Ct. App. 2002
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Rutz v. Rutz
644 N.W.2d 489
Minn. Ct. App. 2002
26, 2000), a denial of, or interference with, visitatióh is not controlling in custody-modification proceedings, but must be considered along with other factors, and argues that visitation problems should not preclude removal.
- Clark v. Clark 543 N.W.2d 685 Minn. Ct. App. 1996
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Clark v. Clark
543 N.W.2d 685
Minn. Ct. App. 1996
597 n. 3 (Minn.App.1994).