Christianson v. Henke, 831 N.W.2d 532

Benton County district court awarded grandparent visitation to paternal grandmother Christianson; Court of Appeals affirmed; Holewa challenges arguing no qualifying proceeding under Minn. Stat. 257C.08; district court treated Recognition of Parentage (ROP) filed under Minn. Stat. 257.75 as a proceeding for parentage under 257C.08, subd. 2; ROP signed by Holewa and Henke established parentage and was filed with the state registrar; November 13, 2010 incident strained the family, leading to petition for grandparent visitation; March 8, 2011 district court order granted limited visitation; Holewa sought to vacate and challenge jurisdiction, arguing ROP is not a proceeding; Court of Appeals affirmed; this Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an ROP qualifies as a proceeding for parentage under 257C.08	Holewa: ROP is not a proceeding; lacks court action	Christianson: ROP is a proceeding; has force of judgment	ROP is a proceeding; district court had jurisdiction

Rohmiller v. Hart, 811 N.W.2d 585 (Minn. 2012) (legislative intent factors support inclusive reading of 'proceeding')
Latourell v. Dempsey, 518 N.W.2d 564 (Minn. 1994) (custody/visitation determinations may constitute a proceeding)
Beardsley v. Garcia, 753 N.W.2d 735 (Minn. 2008) (ROP carries great weight in subject matter jurisdiction for parenting time)
In re D.T.R., 796 N.W.2d 509 (Minn. 2011) (ROP-related issues in parentage context)
In re Child of B.J.-M. & H.W., 744 N.W.2d 669 (Minn. 2008) (ROP effect in related proceedings)
Hohenwald v. State, 815 N.W.2d 823 (Minn. 2012) (definition of 'proceeding' and court work in action)