endangerment standard (Minnesota) · Go Syfert
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endangerment standard in Minnesota

14 Minnesota opinions name it 2 courts 1992–2025 3 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Marriage of Lutzi v. Lutzigreen
minnctapp · 1992 · cited in 2 Minnesota opinions naming this issue, 1993–2001
2 sentences

2001Lutzi v. Lutzi, 485 N.W.2d 311, 315 (Minn.App. 1992).

2001Lutzi v. Lutzi, 485 N.W.2d 311, 315 (Minn.App.1992).

22
Marriage of Crowley v. Meyergreen
minn · 2017 · cited in 2 Minnesota opinions naming this issue, 2018–2024
2 sentences

2024Section 518.18(d)(iv) “governs the modification of custody orders after a judgment and decree.” Crowley v. Meyer, 897 N.W.2d 288, 293 (Minn. 2017).

2018Minn. Stat. § 518.18 (d)(iv) ; Crowley v. Meyer , 897 N.W.2d 288 , 293 (Minn. 2017).

12
In re the Marriage of: Becki Anne Suleski, f/k/a Becki Anne Rupe v. Ryan Michael Rupegreen
minnctapp · 2014 · cited in 1 Minnesota opinions naming this issue, 2017–2017
1 sentence

2017Christensen contends that because his request was a motion to modify parenting time, not a motion to modify the child’s physical custody or primary residence, the district court should have analyzed his request under the best interests standard provided by Minn. Stat. § 518.175 , subd. 5 (2014). 1 “A modification of custody or a change of the child’s primary residence requires that the district court utilize the procedures set forth in Minn. Stat. § 518.18 (d) and associated caselaw.” Suleski v. Rupe, 855 N.W.2d 330, 334-35 (Minn.App. 2014).

11
Marriage of Ayers v. Ayersgreen
minn · 1993 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016“Section 518.18(e) requires the court to apply the endangerment standard in joint custody cases, unless . . . the parties agree in writing to the application of a different standard.” Ayers v. Ayers, 508 N.W.2d 515, 520 (Minn. 1993) (quotation omitted).

11
Marriage of Matson v. Matsongreen
minnctapp · 2002 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016Kaminski argues that the district court erred in denying his motion for sole physical custody, asserting that “if the endangerment standard is met to modify legal custody, it must also have been met to modify physical custody.” In support of his argument, Kaminski cites Matson v. Matson, which states that the standards contained in Minn. Stat. § 518.18 (d) “apply to the modification of legal custody, as well as physical custody.” 638 N.W.2d 462, 467 (Minn. App. 2002).

11
In Re the Marriage of Dahl v. Dahlgreen
minnctapp · 2009 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015Application of Minn. Stat. § 518.175 , subd. 5(a) “Determining the legal standard applicable to a change in parenting time is a question of law and is subject to de novo review.” Dahl v. Dahl, 765 N.W.2d 118, 123 (Minn. App. 2009). “[T]he court shall, upon the request of either parent, grant such parenting time on behalf of the child and a parent as will enable the child and the parent to maintain a child to parent relationship that will be in the best interests of the child.” Minn. Stat. § 518.175 , subd. 1(a) (2014). (a) If modification [of parenting time] would serve the best interests of t

11
Olson v. Olsongreen
minn · 1995 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015Olson v. Olson, 534 N.W.2d 547, 550 (Minn. 1995).

11
Marriage of Ross v. Rossgreen
minnctapp · 1991 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014The district court also ruled that a second prima-facie-case factor was not met because “the facts alleged by [Mitchell] do not rise to the level of endangerment in the 6 child’s present environment.” The endangerment requirement contemplates “a significant degree of danger.” Ross v. Ross, 477 N.W.2d 753, 756 (Minn. App. 1991).

11
Geibe v. Geibegreen
minnctapp · 1997 · cited in 1 Minnesota opinions naming this issue, 2005–2005
1 sentence

2005The endangerment standard requires a “significant degree of danger,” which includes danger purely to emotional and psychological development. 3 Geibe, 571 N.W.2d at 778 (quotation omitted).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Christensen v. Healey (In re M.J.H.) green
minn · 2018
2 sentences

2024The Christensen court addressed a parenting-time dispute in which the parties disagreed about whether the endangerment standard in Minnesota Statutes section 518.18(d)(iv) (2016), or the best-interests-of-the-child standard in Minnesota Statutes section 518.175, subd. 5(b) (2016) applied. 913 N.W.2d at 440–41.

2018ANALYSIS " Minnesota Statutes § 518.18(d)(iv) applies the endangerment standard to modifications of a prior custody order and requires a court to retain the custody arrangement that was established by the prior order unless the party seeking the modification makes a prima facie case for modification." In re M.J.H. , 913 N.W.2d 437 , 440 (Minn. 2018) (quotations omitted).

32018–2025
Christensen v. Healey neutral
minnctapp · 2017
1 sentence

2018Although we conclude that the court of appeals reached the incorrect result, we agree with the court's analysis that "merely increasing Christensen's parenting time to 50 [percent], without more, would not modify the award to Healey of sole physical custody." In re M.J.H. , 899 N.W.2d at 577 .

12018–2018
Marriage of Goldman v. Greenwood green
minn · 2008
1 sentence

2018"Determination of the applicable statutory standard and the interpretation of statutes are questions of law that we review de novo." Goldman v. Greenwood , 748 N.W.2d 279 , 282 (Minn. 2008) (citations omitted).

12018–2018
Dabill v. Dabill green
minnctapp · 1994
1 sentence

2014Dabill v. Dabill, 514 N.W.2d 590 , 595–96 (Minn. App. 1994).

12014–2014
Klecker v. Klecker green
minnctapp · 1990
1 sentence

1992Klecker, 454 N.W.2d at 266-67 .

11992–1992

Statutes the citing opinions construe

MN § Minn. Stat. § 518.18 (11) MN § Minn. Stat. § 518.003 (8) MN § Minn. Stat. § 518.175 (8) MN § Minn. Stat. § 518.17 (7) MN § Minn. Stat. § 480A.08 (4) MN § Minn. Stat. § 518.14 (4) MN § Minn. Stat. § 518.1705 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 71 (2001–2026) CO 30 (1998–2026) IL 24 (1983–2023) IN 15 (1989–2020) MN 14 (1992–2025) NM 4 (2006–2025) MT 3 (1986–1997) MO 2 (1992–1992) AZ 2 (1998–2015) NY 2 (2020–2025) ID 2 (2003–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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