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Marriage of Krech v. Krech
Citations: 624 N.W.2d 310; 2001 Minn. App. LEXIS 368; 2001 WL 345498Docket: C4-00-1530
Court: Court of Appeals of Minnesota; April 10, 2001; Minnesota; State Appellate Court
Daniel James Krech appeals a district court decision to reopen a judgment and decree regarding custody and child support for his daughter, Virginia Louise Krech. The judgment, entered in April 1998, awarded custody and support for their son but did not account for their daughter, who was 19 at the time and had graduated high school. In June 1999, Virginia moved to reopen the decree to seek custody and support for their daughter, citing her learning disability and inability to support herself. The court initially granted support in July 1999 but did not determine custody until July 2000, after which Krech appealed. The central issue is whether the district court had the authority to reopen the judgment and decree 14 months post-entry. The appellate court reviewed the statutory interpretation de novo and acknowledged the district court's discretion in reopening judgments. However, it ultimately concluded that the district court lacked authority under Minn. Stat. 518.145, subd. 2, to impose new obligations without meeting statutory requirements. The court defined "child" as individuals under 18, those under 20 still in secondary school, or individuals unable to support themselves due to physical or mental conditions. Despite the daughter's circumstances, the court found that the reopening did not comply with statutory provisions, leading to a reversal of the district court's order. The court may relieve a party from a judgment and decree under certain circumstances outlined in Minn. Stat. 518.145, subd. 2, which include: 1) mistake, inadvertence, surprise, or excusable neglect; 2) newly discovered evidence; 3) fraud or misconduct by an opposing party; 4) a void judgment; or 5) conditions where the judgment has been satisfied, reversed, or is no longer equitable. A motion for relief must be filed within a reasonable time, typically no more than one year for reasons under clauses (1), (2), or (3). In this case, the respondent's motion was filed over a year after the judgment, disqualifying clauses (1), (2), and (3), and the respondent did not claim the judgment was void, leaving clause (5) as the only potential basis for relief. Clause (5) allows reopening only if the judgment has been satisfied, based on a prior judgment that has been reversed, or if it is inequitable for the judgment to apply prospectively. Although the equity argument could suggest a need for continued parental obligations, the principle of ejusdem generis limits the interpretation of clause (5) to obligations that have been extinguished or reduced, not to add new provisions. Thus, the court concluded it lacked authority to reopen the judgment and impose new obligations for custody and child support. Consequently, the district court's actions were reversed, and the sanctions against the appellant for failure to pay child support were also overturned.