Cited by

of Coats, (stating that supreme court reviews a district court ’s decision to deny relief under Minn. R. Civ.

of Coats, d 505, 510 (Minn. 2001).

of Coats , (stating that appellate courts “consider only those issues that were presented and considered by the [district] court”) ; see also In re Welfare of C.L.L.

(providing that appellate courts “consider only those issues that were presented and considered by the [district] court”); (declining to address a constitutional issue raised for the first time on appeal from a termination of parental righ

of Coats, (applying Minnesota Rule of Civil Procedure 60.02 — which was effective before the predecessor of the current rule 22.02 was promulgated—to consider a mother’s motion to vacate a default order terminating her parental rights).

of Coats, (providing that appellate courts generally “consider only those issues that were presented and considered by the [district] court”); see also In re Welfare of Child.

of Coats, (quotation omitted).

of Coats, (); see In re Welfare of Child.

of Coats, 512 (Minn. 2001) (applying Thiele in the TPR context to hold appellant’s due-process claim was forfeited).

Wife responds that husband’s “statements are conclusory.” Wife is correct that a reasonable defense on the merits must be suppor ted by “mo re than conclusory statements.” In re Welfare of Children of Coats

11 We have applied the rules of civil procedure on occasion in juve nile protection matters, including in the context of proceedings in which a parent has defaulted by failing to appear.4 (considering whether the district court erred in denying a parent’s motion under Minn. R. Civ.

A reasonable defense on the merits must be supported by “more than conclusory statements.” (quotation omitted).

In re Welfare of Children of Coats , & n.4 (Minn. 2001) (applying, before the predecessor of the current Minn. R. Juv.

In the supreme court held that “a judgment will be held void for want of due process only where the circum stances surrounding the trial are such as to make it a sham and a pretense rather than a real judicial proceeding.” Id.

The amount of process due varies with the circumstances of the case.’” In re Welfare of Children of Coats , ().

In , the supreme court held that “‘a judgment will be he ld void for want of due process only where the circumstances surrounding the trial are such as to make it a sham and a pretense rather than a real judicial proceeding.’” Id.

P. 60.02 and factors that party must demonstrate to be relieved from consequences of attorney’s neglect); (applying Minn. R. Civ.

Id., 18.02; see also In re Welfare of Children of Coats , –12 (Minn. 2001) (addressi ng vacation of termination of parental rights by default).

Due-Process Rights “[A] judgment will be held void for want of due process only where the circumstances surrounding the trial are such as to make it a sham and a pretense rather than a real judicial proceeding.” In re Welfare of Children of Coats

P. 18.02; see also In re Children of Coats , (addressing vacation of a termination of parental rights by default).

see also In re Welfare of Children of Coats , (applying waiver analysis to termination proceeding).

See, e.g., In re Welfare of Children of Coats

Hinz v. Northland Milk & Ice Cream Co., 237 Minn. 28, 30, (applying Minn. R. Civ.

also contends that the district court erred by denying her post-trial motion on the ground that she satisfied the four-factor test for relief from a default judgment that was articulated in : (1) she has a reasonable defense on the merits of the case; (2) she has a reasonable excuse for her failure to act; (3) she acted with due diligence after the notice of entry of the default judgment; and (4) the opposing party will not be substantially prejudiced if the motion to vacate the default

A violation of due process occurs only if “the circumstances surrounding the trial [or hearing] are such as to make it a sham and a pretense rather than a real judicial proceeding.”

Nguyen, d at 490; (same); Pedersen v. Daly, 307 Minn. 163, 165, (declaring that the movant is “obliged to affirmatively establish all of the [Finden requirements]”).

at 491; (reasoning that the district court properly concluded 3 We have not yet decided whether a plaintiff seeking Rule 60.02 relief may rely entirely on the well-pleaded facts of the complaint in establishing a debatably meritorious claim, or whether an affidavit outside of the pleadings is nee

“It is well settled that where the trial court has jurisdiction of the offense and of the defendant a judgment will be held void for want of due process only where the circumstances surrounding the trial are such to make it a sham and a pretense rather than a real judicial proceeding.” (quotation omitted).