In re the Marriage of: Abdihafid Hariri Hassan Yusuf, petitioner, Appellant, vs. Neama Omar Y Al Somali, Respondent. ..., a251979

Background

Father and mother married in 2019, have one child born in 2020, separated in 2021, and engaged in extensive dissolution and OFP litigation. 1
The district court issued an OFP for mother, granted her temporary sole custody, and later deemed father a frivolous litigant in the OFP matter. 2
In April 2024, the dissolution decree awarded mother sole custody, father supervised parenting time at FamilyWise, and child support based on imputed income. 3
This court affirmed the dissolution decree in March 2025. 4
Afterward, father filed motions to reduce support, modify parenting time and custody-related restrictions, and obtain tax-exemption and safety relief; the district court denied them and again found him frivolous. 5

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Frivolous-litigant designation 6	Father said his motions were made in good faith and lesser sanctions sufficed.	Mother said father repeatedly relitigated rejected issues and burdened the court.	Affirmed; district court properly applied Rule 9.06(b). 7
Modify parenting time 8	Father sought unsupervised or alternative supervised parenting time and blamed cost.	Mother said father had not met decree requirements and proposed changes were not child-centered.	Affirmed; no abuse of discretion. 9
Modify child support and child care support 10	Father claimed lower income, a bona fide career change, and reduced child-care costs.	Mother said he remained voluntarily underemployed and proved no changed expenses.	Affirmed; father failed to show a qualifying substantial change. 11
Safety-related order 12	Father wanted restrictions on the child being alone with mother’s brother and traveling to Saudi Arabia.	Mother said father offered no credible evidence of danger.	Affirmed; district court’s no-credible-evidence finding was not clearly erroneous. 13
Tax dependency exemption 14	Father sought alternating tax exemption and broader equitable relief.	Mother said father had under ten percent parenting time and no agreement for alternation.	Affirmed; father was statutorily ineligible. 15

Key Cases Cited

Fitzgerald v. Fitzgerald, 629 N.W.2d 115 (Minn. App. 2001) (self-represented litigants generally must comply with court rules 16)
Schoepke v. Alexander Smith & Sons Carpet Co., 187 N.W.2d 133 (Minn. 1971) (unsupported assignments of error are waived absent obvious prejudice 17)
Midway Ctr. Assocs. v. Midway Ctr., Inc., 237 N.W.2d 76 (Minn. 1975) (appellant bears the burden of showing error 18)
Sarzynski v. Szarzynski, 732 N.W.2d 285 (Minn. App. 2007) (frivolous-litigant determinations reviewed for abuse of discretion 19)
Woolsey v. Woolsey, 975 N.W.2d 502 (Minn. 2022) (defines abuse of discretion review for family-law orders 20)
Sefkow v. Sefkow, 427 N.W.2d 203 (Minn. 1988) (appellate courts do not reweigh evidence or credibility 21)
Hansen v. Todnem, 908 N.W.2d 592 (Minn. 2018) (parenting-time modification turns on the child’s best interests and need not include detailed factor findings 22)
Hecker v. Hecker, 568 N.W.2d 705 (Minn. 1997) (moving party must prove a substantial change making support unreasonable and unfair 23)
Ulrich v. Ulrich, 400 N.W.2d 213 (Minn. App. 1987) (voluntary underemployment cannot justify reduced support 24)
Putz v. Putz, 645 N.W.2d 343 (Minn. 2002) (speculative future earnings do not prove a bona fide career change 25)
Kenney, In re Civil Commitment of, 963 N.W.2d 214 (Minn. 2021) (clear-error review is deferential to the factfinder 26)
Ludwigson v. Ludwigson, 642 N.W.2d 441 (Minn. App. 2002) (tax dependency exemptions are within the district court’s discretion 27)
Thiele v. Stich, 425 N.W.2d 580 (Minn. 1988) (issues not raised and considered below are not reviewed on appeal 28)
Ganguli v. University of Minnesota, 512 N.W.2d 918 (Minn. App. 1994) (inadequately supported arguments are not addressed on appeal 29)
Melina v. Chaplin, 327 N.W.2d 19 (Minn. 1982) (inadequately briefed issues are not properly before the court 30)
Emerson v. School Board of Independent School District 199, 809 N.W.2d 679 (Minn. 2012) (issues raised for the first time in a reply brief are generally not considered 31)