Blomdahl v. Blomdahl, 796 N.W.2d 649

Divorce judgment (Feb. 1993) awarded Mary 90% interest in Russell's retirement accounts; stipulation incorporated by judgment.
Mary did not enforce or renew the judgment for years; demanded payment in 2009 after Russell allegedly shifted or depleted funds.
District court held the judgment was unenforceable after ten years without renewal, so contempt under 14-05-25.1 could not be maintained.
Court treated contempt under 14-05-25.1 as a special proceeding, not an action on the judgment under 28-01-15(1), so the ten-year limit did not govern the contempt remedy.
Majority affirmed the denial of contempt; dissent would hold the ten-year limit tolled until pay status, allowing contempt post-2003.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether contempt under 14-05-25.1 is an action on the judgment for 28-01-15(1).	Blomdahl argued contempt is within 28-01-15(1) and time-barred.	Respondent contends contempt is a special proceeding not subject to that statute.	Contempt is a special proceeding, not an action on the judgment; ten-year limit not controlling.
Whether the divorce judgment awarding Mary’s retirement interest expired, preventing contempt.	Mary contends the judgment remained enforceable via contempt.	Jurisdiction ended as the judgment expired after ten years without renewal.	The judgment expired after ten years without renewal; contempt not permissible under the majority view.

Seablom v. Seablom, 348 N.W.2d 920 (N.D. 1984) (civil contempt not proper for enforcement of property distribution prior to 14-05-25.1)
Leifert v. Wolfer, 24 N.W.2d 690 (N.D. 1946) (execution based on an unrenewed divorce judgment may be extinguished; continuation of alimony can differ from property liens)
Fuson v. Schaible, 494 N.W.2d 593 (N.D. 1992) (ten-year renewal principles apply to judgments for property division; timing matters for enforcement)
Giese v. Giese, 676 N.W.2d 794 (N.D. 2004) (former wife's right to retirement benefits via divorce decree; contempt for willful violation)