Cited by

-44 (Minn. 1994); see also Minn. Stat. §§ 518.17, subd.

n.1 (Minn. 1994) 9 (describing the law of the case as a discretionary doctrine developed by appellate courts to effectuate the finality of appellate decisions, and “is not normally applied by a trial court to its own prior decisions”).

31, 2024) ( n.1 (Minn. 1994)).

n.1 (Minn. 1994) (citation omitted).

7 For this reason, we do not address father’s res judicata and collateral estoppel arguments except to note that “the availability and application of res judicata and collateral estoppel in family matters is limited.” Maschoff v. Leiding , see Loo v. Loo , , 743 -44, 744 n.1 (Minn .

trict c ]ourt from addressing the issue of permanent spousal maint enance now” and that “where a [c]ourt establishes temporary spousal maintenance and reserves permanent spousal maintenance, the motion for permanent spousal maintenance must be made before the end of the temporary maintenance obligation.” The district court cited four cases that support respondent’s argument: (“Once maintenance payments end, the [district] court is without jurisdiction to modify maintenance.”); (“[T]here cannot b

See, n.1 (Minn. 1994) (“Res judicata, or claim preclusion, prevents parties from splitting claims into more than one lawsuit and precludes further litigation of the same claim.”).

n.1 (Minn. 1994) (noting “law of the case .

d 829, 837 (Minn. 2004) (“[N]either res judicata nor collateral estoppel is to be rigidly applied.”); Bode, d at 868 (analyzing a collateral attack according to “competing principles of finality and validity”); n.1 (Minn. 1994) (explaining that law of the case is a “discretionary doctrine”); Levine v. Bayview Loan Servicing, LLC, (explaining that “comity is a principle taken into account when addressing whether to apply the first-to-file rule,” which

6 d 740, 743-44 (Minn. 1994) (reasoning that “[a]lthough none of the principles or doctrine requiring that judicial decisions have preclusive effect appl[ied] to this case in a technical sense,” if the respondent’s motion required adjudication of an issue that was litigated and 6 Before the probate court and on appeal

developed by the appellate courts to effectuate the finality of appellate decisions” and “is not normally applied by a trial court to its own prior decisions.” n.1 (Minn. 1994) (citation omitted); (citing Loo in declining to apply the law-of-the-case doctrine to the district court’s prior ruling), rev. granted (Minn. Aug.

The availability and application of res judicata in family -law matters is limited, but “the underlying principle that an adjudication on the merits of an issue is conclusive, and should not be relitigated, clearly applies.”

-04 (Minn. 1989) (holding that parties may waive the right to modify maintenance); Minn. Stat. § 518.552, subd.

App. P. 140.01 (“No petition for rehearing shall be allowed in the Court of Appeals.”); n.1 (Minn. 1994) (stating law -of-the-case doctrine “ordinarily applies where an appellate court has ruled on a legal issue and has remanded the case to the lower court for further proceedings”).

“The doctrine of law of the case is a rule of practice followed between the Minnesota appellate courts and the lower courts.” n.1 (Minn. 1994).

26, 1997); -44 & n.1 (Minn. 1994) (explaining that preclusive effect must be given to a matter decided in a final spousal-maintenance order 10 when a later motion to modify spousal maintenance seeks to relitigate an issue decided in the previous order).

The law-of-the-case doctrine is a well -established rule intended to “effec tuate the finality of appellate decisions.” n.1 (Minn. 1994).

Doran v. Kennedy, 237 U.S. 362, 368 (1915), d 623, 629 (Minn. 1949) (rejecting collateral attack on a probate distribution and stating that the decree of a probate court is binding “w hether right or wrong” unless reversed or modified on appeal); see also Loo v. Loo , -44 (Minn. 1994) (noting that “the underlying principle that an adjudication on the merits of an issue is conclusive, and should not be relitigated, clearly applies” even when res judicata, collateral estoppel, and law of the case

n. 1 (Minn. 1994) (“The doctrine of law of the case is a rule of practice followed between the Minnesota appellate courts and the lower courts .

’r of Revenue, (observing that “the availability and application of res judicata and collateral estoppel in family matters is limited, but ‘the underlying principle that an adjudication on the merits of an issue is conclusive, and should not be relitigated, clearly applies’”) ().

The law-of-the-case doctrine is intended to “effectuate the finality of appellate decisions.” Loo v. Loo , n.1 (Minn. 1994); see also Sylvester II, d at 795 (observing that the doctrine is “based on a policy requiring issues once fully litigated to be set at rest”).

The legislature has given the district courts continuing jurisdiction over family law proceedings by allowing modifications to orders, and “parties may always move for such modifications based on changed circumstances.”

See Loo v. Loo , -44 (Minn. 1994) (discussing how changing circumstances, inherent in family law matters, limit the applicability of collateral 5 “Res judicata is distinct from collateral estoppel, also known as issue preclusion, which precludes a party from relitigating an issue

The district court is “a third party to dissolu tion actions” and, as a third party, has a duty “to protect the interests of both parties” and “to ensure that the s tipulation is fair and reasonable to all.” (quotation omitted).

T he 2017 judgment did not explicitly 1 See Loo v. Loo , 3-44 (Minn. 1994) (noting that, “[i ]n a technical sense,” res judicata does not apply in spousal-maintenance dispute because there is no final judgment in another suit , but acknowledging that “t he underlying principle that an adjudication on the merits of an issue is conclusive, and should not be relitigated

Loo v. Loo , (“The legislature has given the trial courts continuing jurisdiction over dissolution proceedings by allowing modifications in .

See also Loo v. Loo , -46 (Minn. 1994) (noting additional statutory requirements for valid waivers of spousal maintenance modification rights).

n.1 (Minn. 19 94) (the doctrine of law of the case “applies where an appellate court has ruled on a legal issue and has remanded the case to the lower court for further proceedings”).

However, the law -of-the-case doctrine is a “discretionary doctrine developed by the appellate courts to effectuate the finality of appellate decisions.” n.1 (Minn. 1994) .

Moreover, law of the case “is not normally applied by a trial court to its own prior decisions.” n.1 (Minn. 1994); see Kornberg, d at 386 n.2 (citing this aspect of Loo).

prevents parties from splitting claims into more than one lawsuit and precludes further litigation of the same claim.” n.1 (Minn. 1994).

-44 (Minn. 1994) (noting that, while “in a technical sense” res judicata and collateral estoppel do not apply to modification motions in family cases, “the underlying principle that an adjudication on the merits of an issue is and should not be relitigated, clearly applies”).

Loo v. Loo , -44 (Minn. 1994).

744 n.1 (Minn. 1994) (citations omitted); , 305 n.7 (Minn. 2008) (“The law-of-the-case doctrine is a rule of practice that once an issue is considered and adjudicated, that issue should not be reexamined in that court or any lower court throughout the case.” (quotation *832 omitte

App. P. 103.04 (providing that this court “may review any order affecting the order from which the appeal is taken”); –44 (Minn. 1994) (stating that parties to a dissolution may 10 always move to modify maintenance, but “decisions on other issues litigated and determined in the course of deciding such motions should be given preclusive effect”).

See, (“Once maintenance payments end, the court is without jurisdiction to modify maintenance.”); Eckert v. Eckert, 299 Minn. 120, 125, d 837, 840 (1974) (“[W]here the decree does not specifically reserve jurisdiction of the issue of alimony for determination at a later date, no such jurisdict

n.1 (Minn. 1994); n.2 (Minn. 1996) (noting that the law-of-the-case doctrine “is not normally applied by a district court to its own decisions” (citing Loo, d at 744 n.1)).