Cited by

Hecker v. Hecker , n.2 (Minn. App. 1996), aff’d

See Hecker v. Hecker , (establishing that a district court may impute income to an individual who had willfully failed to rehabilitate), aff’d

the record is extensive.” Hecker v. Hecker , n.2 (Minn. App. 1996), aff’d

Hecker v. Hecker , n.2 (Minn. App. 1996), aff’d, (refusing to consider portions of a pro se brief that contained only argument and that was unsupported by the facts in the record).

2 (Supp. 2024), a party seeking modification of spousal maintenance bears the burden of showing “a substantial change in one or more of the circumstances identified in the statute,” and then “show[ing] that the substantial change [renders] the original award unreasonable and unfair.” d 705, 709 (Minn. 1997) (addressing prior version of statute).

Whether there has been a substantial change of circumstances since the previous order is a threshold question in a motion to modify maintenance, and the circumstances that existed at the time of the original decree serve as “the baseline circumstances against which claims of substantial change are evaluated.” Hecker v. Hecker

the record is extensive”) aff’d, d 364, 371-72 (Minn. App. 1998) (noting that failure to cite to the record can result in non- consideration of an issue).

d 705, 709 (Minn. 1997).

the record is extensive”) aff’d, -72 (Minn. App. 1998) (noting that failure to cite to the record can result in an argument not being properly before this court).

for an abuse of discretion.” (citing Hecker v. Hecker , ).

n.2 (Minn. App. 1996), aff’d, (stating that factual assertions “are to be supported by a cite to the record”).

8 unreasonable and unfair.” See Hecker v. Hecker , (addressing prior version of the statute).

Absent a prior modification order, t he terms of the dissolution decree provide “the baseline circumstances against which claims of substantial change are evaluated.”

d 678, 681 n.2 (Minn. App. 1996), aff’d, (refusing to consider portions of pro se briefs that contain only argument and are not supported by the facts in the record).

1(c); - 82 n.2 (Minn. App. 1996) (noting “material assertions of fact in a brief properly are to be supported by a cite to the record” and stating such cites are “particularly important” where “the record is extensive”), aff’d

Hecker v. Hecker , - 10 (Minn. 1997).

the record is extensive”), aff’d, -72 (Minn. App. 1998) (noting that failure to cite the record can result in an argument not being properly before this court).

(concluding that pro se defendant’s assertions are waived if they contain no argument or legal authority to support allegations); Hecker v. Hecker , n.2 (Minn. App. 1996) (requiring that material assertions of fact be supported by citation to the record), aff’d, d 705 (Minn. 1997); (concluding that appellate courts “generally will not decide issues which were not raised before the district court”).

the record is extensive.” Hecker v. Hecker , n.2 (Minn. App. 1996), aff’d

(affirming the district court because, even assuming error, that error would be “nonprejudical”), aff’d

Hecker v. Hecker , see also Minn. Stat. § 518A.39, subd.

Hecker v. Hecker , n.4 (Minn. 1997) (“[The supreme court has] recognized an implicit requirement that a temporary maintenance recipient make a reasonable effort to become self- supporting in accordance with the expectations of the parties.”) ().

A stipulation provides the “baseline circumstances against which claims of substantial change are evaluated.” (making this statement in the conte xt of a modification order) .

the record is extensive.” n.2 (Minn. App. 1996), aff’d, .

Hecker v. Hecker , d 705, 710 (Minn. 1997).

Minn. Stat. § 518A.39 (2020); , 709 (Minn. 1997).

-10 n.4 (Minn. 1997); Maiers, d at 669.

See Hecker v. Hecker , (making a similar observation in the context of a motion to modify maintenance).