best-interest factors in Minnesota

2024See Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988) (“A reviewing court must generally consider only those issues that the record shows were presented and considered by the [district] court in deciding the matter before it.” (quotation omitted)). 8 Here, mother contends that the district court failed to make findings on all of the best-interest factors enumerated by section 518.17.

2017See Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988); Szarzynski v. Szarzynski, 732 N.W.2d 285, 293 (Minn. App. 2007). 10 F. Bowman argues that the district court erred by not considering the best-interest factors or by concluding that the best-interest factors favored an award of custody over L.W. to Wieczorek.

2016Best-interest factors Because the district court has broad discretion in deciding what is in the best interests of the children, there is “scant if any room for an appellate court to question the [district] court’s balancing of best-interests considerations.” Vangsness, 607 N.W.2d at 477 .

2015Best-interest factors Because the district court has broad discretion in deciding what is in the best interests of the children, there is “scant if any room for an appellate court to question the [district] court’s balancing of best-interests considerations.” Id. at 477 .

2011Just as a finding that visitation would be in a child’s best interests does not justify adding to a statute’s language, it does not justify superseding the parent’s wish. “[O]ne of the dangers of utilizing a best-interest analysis is the potential for a court to make the decision based entirely on the court’s subjective estimation without regard to the fit parent’s wishes.” Id. at 823 (citing Troxel, 530 U.S. at 67 , 120 S.Ct. at 2061 (condemning situation in which, “[s]hould the judge disagree with the parent’s estimation of the child’s best interests, the judge’s view necessarily prevails”))

2011Just as a finding that visitation would be in a child’s best interests does not justify adding to a statute’s language, it does not justify superseding the parent’s wish. “[O]ne of the dangers of utilizing a best-interest analysis is the potential for a court to make the decision based entirely on the court’s subjective estimation without regard to the fit parent’s wishes.” Id. at 823 (citing Troxel, 530 U.S. at 67 , 120 S.Ct. at 2061 (condemning situation in which, “[s]hould the judge disagree with the parent’s estimation of the child’s best interests, the judge’s view necessarily prevails”))

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).

2024Id.; see also Hansen, 908 N.W.2d at 597 (holding that, upon consideration of a motion to modify parenting time, a district court must only consider the relevant best- interest factors and need not make specific findings on each factor).

2024We therefore conclude that our inquiry is not whether the district court made findings on all of the section 518.17 best-interest factors, but rather whether the district court made “sufficient findings to enable appellate review.” See Hansen, 908 N.W.2d at 597 n. 2.

2024A best-interest analysis requires consideration of three factors: “(1) the child’s interest in preserving the parent-child relationship; (2) the parent’s interest in preserving the parent-child relationship; and (3) any competing interest of the child.” In re Welfare of Child of W.L.P., 678 N.W.2d 703, 711 (Minn. App. 2004) (quotation omitted); see Minn. R.

2018See Rasmussen v. Two Harbors Fish Co. , 832 N.W.2d 790 , 797 (Minn. 2013).

2017See Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988); Szarzynski v. Szarzynski, 732 N.W.2d 285, 293 (Minn. App. 2007). 10 F. Bowman argues that the district court erred by not considering the best-interest factors or by concluding that the best-interest factors favored an award of custody over L.W. to Wieczorek.

2015See Goldman, 748 N.W.2d at 284 (stating that we may review whether the district court misapplied the law).

2010See Lutzi v. Lutzi, 485 N.W.2d 311, 315 (Minn.App.1992) (stating that, under subdivision 5, the best-interest standard governs modifications except in cases of "more substantial reductions of visitation," and that a restriction involves "greater alteration of visitation rights”).