stipulation bar (Minnesota) · Go Syfert
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stipulation bar in Minnesota

6 Minnesota opinions name it 2 courts 1985–2015 0 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 (5)

CaseFollowedCited
Marriage of Simmons v. Simmonsgreen
minnctapp · 1992 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015Because child support “relates to nonbargainable interests of children,” it is “less subject to restraint by stipulation than are other dissolution matters.” Id. (quotations omitted); see also Simmons v. Simmons, 486 N.W.2d 788 , 791–92 (Minn. App. 1992) (noting that the welfare of children takes precedence over any stipulated provision in a dissolution judgment). 11 Nonetheless, this court has held that a stipulated judgment, with findings, may rebut a presumption of unfairness and unreasonableness in a support-modification proceeding.

11
Marriage of O'Donnell v. O'Donnellgreen
minnctapp · 2004 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015Minn. Stat. § 518A.39, subd. 2(b)(1). “[T]he existence of a stipulation does not bar later consideration of whether a change in circumstances warrants modification.” O’Donnell v. O’Donnell, 678 N.W.2d 471, 475 (Minn. App. 2004) (quotation omitted).

2015Because child support “relates to nonbargainable interests of children,” it is “less subject to restraint by stipulation than are other dissolution matters.” Id. (quotations omitted); see also Simmons v. Simmons, 486 N.W.2d 788 , 791–92 (Minn. App. 1992) (noting that the welfare of children takes precedence over any stipulated provision in a dissolution judgment). 11 Nonetheless, this court has held that a stipulated judgment, with findings, may rebut a presumption of unfairness and unreasonableness in a support-modification proceeding.

11
Marriage of Yeager v. Yeagergreen
minnctapp · 1987 · cited in 1 Minnesota opinions naming this issue, 1989–1989
2 sentences

1989See id. at 523 n. 2, which includes a warning of the potential risk of relying on judgment where the matter is "presented to the court on a stipulation with a waiver of both counsel and appearance." We recognize the seriousness of the concerns raised in Yeager and in the special concurrence here regarding the integrity of stipulations based upon waiver of counsel and nonappearance of a pro se party.

1989See id. at 523 n. 2, which includes a warning of the potential risk of relying on judgment where the matter is “presented to the court on a stipulation with a waiver of both counsel and appearance.” We recognize the seriousness of the concerns raised in Yeager and in the special concurrence here regarding the integrity of stipulations based upon waiver of counsel and nonappearance of a pro se party.

11
State v. Wahlgreen
minnctapp · 1986 · cited in 1 Minnesota opinions naming this issue, 1987–1987
1 sentence

1987See State v. Wahl, 394 N.W.2d 536, 538 (Minn.Ct.App.1986), pet. for rev. denied (Minn. Nov. 19, 1986) (prosecutor and defense counsel agreed on statement summarizing factual basis of Spreigl conviction).

11
Kaiser v. Kaisergreen
minn · 1971 · cited in 1 Minnesota opinions naming this issue, 1985–1985
2 sentences

1985Kaiser v. Kaiser, 290 Minn. 173, 180-81 , 186 N.W.2d 678, 683 (1971).

1985Kaiser v. Kaiser, 290 Minn. 173, 180-81 , 186 N.W.2d 678, 683 (1971).

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 (2)

CaseCitedYears
State v. Davidson green
minn · 1984
2 sentences

2007In evaluating whether Davidson’s case warranted application of the exception to the general rule, and thus whether the trial court’s refusal to accept the stipulation was error, we explained that when the potential for unfair prejudice is high: “the correct approach under the Rules of Evidence in a ease such as [Davidson’s is] to compare the potential of the evidence for unfair prejudice with the relevance of the evidence to issues other than the issue to which the stipulation relates.” Id. at 11-12 .

2007In evaluating whether Davidson's case warranted application of the exception to the general rule, and thus whether the trial court's refusal to accept the stipulation was error, we explained that when the potential for unfair prejudice is high: "the correct approach under the Rules of Evidence in a case such as [Davidson's is] to compare the potential of the evidence for unfair prejudice with the relevance of the evidence to issues other than the issue to which the stipulation relates." Id. at 11-12 .

12007–2007
State v. Lothenbach green
minn · 1980
1 sentence

1998Lothenbach, 296 N.W.2d at 857 .

11998–1998

Where else courts name it

CA 45 (1925–2025) NY 25 (1897–2025) IA 13 (1902–2021) FL 12 (1992–2026) IL 11 (1943–2026) TX 9 (1917–2022) PA 8 (1883–2022) IN 6 (1981–2026) DC 6 (1984–2015) WA 6 (1915–2025) NJ 6 (1953–2024) OH 6 (1917–2026) MN 6 (1985–2015) MI 6 (1897–2023) NC 5 (1959–2019) LA 5 (1967–2019) CO 5 (1891–2017) OK 5 (1953–2010) MA 5 (1971–2000) ID 4 (1906–2013) HI 4 (2012–2019) WI 4 (1978–2005) AZ 4 (1968–2019) CT 4 (1931–1989) KS 3 (1956–2021) AR 3 (1981–2020) NM 3 (1969–2018) MD 3 (1911–2018) KY 2 (1897–2023) UT 2 (1992–2000) AK 2 (2010–2024) GA 2 (1947–2005)

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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