Minnesota Statutes

Minn. Stat. § 518A.37 (2026)

Written Findings

✓ current as of May 2026

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Subdivision 1.No deviation.

If the court does not deviate from the presumptive child support obligation computed under section 518A.34, the court must make written findings that state:

(1) each parent's gross income;

(2) each parent's PICS; and

(3) any other significant evidentiary factors affecting the child support determination.

Subd. 2.Deviation.

If the court deviates from the presumptive child support obligation computed under section 518A.34, the court must make written findings that state:

(1) each parent's gross income;

(2) each parent's PICS;

(3) the amount of the child support obligation computed under section 518A.34;

(4) the reasons for the deviation; and

(5) how the deviation serves the best interests of the child.

Subd. 3.Written findings required in every case.

The provisions of this section apply whether or not the parties are each represented by independent counsel and have entered into a written agreement. The court must review stipulations presented to it for conformity with section 518A.34. The court is not required to conduct a hearing, but the parties must provide sufficient documentation to verify the child support determination and to justify any deviation.

Notes of Decisions

Cited in 12 cases (2 in the last 5 years), 2009–2025 · leading case: Marriage of Haefele v. Haefele, 837 N.W.2d 703 (Minn. 2013).

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Marriage of Haefele v. Haefele, 837 N.W.2d 703 (Minn. 2013). · cites it 4× “” Minn.Stat. § 518A.37, subd. 2(4)-(5). As noted above, in order to determine the presumptive child-support obligation, the court must calculate “the gross income of each parent.”

In re the Matter of: Dakota Cnty., Lorinda Elaine Floding, Below v. Darrell Ray Gillespie, 866 N.W.2d 905 (Minn. 2015). · cites it 8× “” Minn. Stat. § 518A.37, subd. 2. The result is the final child support order.”

Marriage of Hesse v. Hesse, 778 N.W.2d 98 (Minn. Ct. App. 2009). · cites it 2× “See Minn.Stat. § 518A.37, subd. 2(5) (2008) (stating that an order deviating from the presumptive child-support obligation requires findings on the best interests of the child).”

Cnty. of Dakota, ex rel., Michelle Marie Hinz v. Bryan Arthur ... (Minn. Ct. App. 2025). · cites it 8× “Minn. Stat. § 518A.37, subd. 2 (2024). In her order, the CSM set Rittweger’s monthly arrearage payment amount with “no credit for parenting time.”

Leslie E. Sheehy Lee, Appellant, vs. Travis W. Kalis, Respondent, Cnty. of Le Sueur, Respondent (Minn. 2025). · cites it 8× “See Minn. Stat. § 518A.37, subds. 1, 2 (stating that “the court must make written findings” (emphasis added)).”

In re the Marriage of: Stacy Elizabeth Reeves v. Brian Lawrence Reeves, Hennepin Cnty., intervenor (Minn. Ct. App. 2015). · cites it 4× “Minn. Stat. § 518A.37, subd. 2 (2014). Here, after determining that father is unemployed but no longer receiving unemployment benefits, the district court calculated father’s support obligation based on his actual gross income of $0.”

In re the Marriage of: Emily-Jean Chinwendu Aguocha v. Ikechukwu Hisa Aguocha (Minn. Ct. App. 2016). · cites it 2× “The district court also made written findings as required by Minn. Stat. § 518A.37 (2014). Appellant testified at trial and also submitted a financial affidavit stating that his average monthly income was about $4,000.”

In re the Marriage of: Kathleen Jean Rucker v. Kraig Vernon Rucker (Minn. Ct. App. 2016). · cites it 2× “” Minn. Stat. § 518A.37, subd. 2(5) (2014).”

In re the Custody of M. M. L. Nathan James Sands v. Sue Mae Lovick, Dakota Cnty. (Minn. Ct. App. 2016). · cites it 2× “Minn. Stat. § 518A.37 (2014). Potential income is calculated according to one of three methods: (1) the parent’s probable earnings level based on employment potential, recent work history, and occupational qualifications in light of prevailing job opportunities and earnings…”

In re the Marriage of: Dawn Marie Mondus Loger v. Cory Scott Loger (Minn. Ct. App. 2014). · cites it 2× “” Minn. Stat. § 518A.37, subd. 2 (2012). After entry of default judgment, the parties stipulated that “mutually agreed upon” expenses under paragraph 6.”

Michael Charles Sasse, f/k/a Michael Charles Sasse Penkert v. Kathryn Elizabeth Penkert, f/k/a Delight Bernice Penkert (Minn. Ct. App. 2015). · cites it 2× “2013) (citing Minn. Stat. §§ 518A.37, subd. 2, 518A.43, subd.”

In re the Marriage of: Diane Drays Hill v. Michael C. Hill (Minn. Ct. App. 2015). · cites it 2× “Father 9 failed to show how lowering his child-support obligation would be in the children’s best interest under Minn. Stat. § 518A.37, subd. 2(5) (2014).”

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