Marriage of Knapp v. Knapp
883 N.W.2d 833
Minn. Ct. App.2016Background
- James and Marla Knapp married in 1975; Marla filed for dissolution in 2014. James accepted service but did not answer or appear at scheduled court dates.
- Marla obtained a default dissolution judgment on August 25, 2014; James was mailed notice of entry.
- About a year later (August 13, 2015) James moved to vacate the default judgment under Minn. Stat. § 518.145, subd. 2(1), claiming mental-health hospitalization in June 2014 (excusable neglect) and alleging Marla undervalued assets and understated income.
- The district court treated James’s claims as alleging excusable neglect, heard conflicting affidavits, credited Marla’s account that James was aware of proceedings, and denied the motion without addressing Minn. R. Civ. P. 60.02.
- James appealed, arguing the court abused its discretion by failing to consider Rule 60.02 factors in addition to § 518.145.
- The appellate court reviewed whether the district court abused its discretion in denying relief under § 518.145 and whether it was required to address Rule 60.02.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion by denying motion to vacate under Minn. Stat. § 518.145 for excusable neglect | James: his hospitalization and mental-health issues amounted to excusable neglect and justify vacatur; property division was inequitable | Marla: James was aware of proceedings, communicated he would not attend, and default was not excusable; court need only apply § 518.145 | Court: No abuse of discretion; district court reasonably credited Marla and found James failed to prove excusable neglect under § 518.145 |
| Whether district court was required to consider Minn. R. Civ. P. 60.02 in addition to § 518.145 | James: district court should have addressed Rule 60.02 factors | Marla: Rule 60.02 is not the proper vehicle for vacating divorce decrees; § 518.145 controls | Court: No. Appellate precedent treats § 518.145 as the proper and exclusive statutory vehicle; court did not need to address Rule 60.02 |
Key Cases Cited
- Thompson v. Thompson, 739 N.W.2d 424 (Minn. Ct. App. 2007) (dissolution decree final when entered absent timely statutory motion)
- Kornberg v. Kornberg, 542 N.W.2d 379 (Minn. 1996) (appellate review standard for denying reopening of judgment)
- Shirk v. Shirk, 561 N.W.2d 519 (Minn. 1997) (sole relief from dissolution judgment lies in Minn. Stat. § 518.145; statute parallels Rule 60.02 but governs dissolution decrees)
- Lindsey v. Lindsey, 388 N.W.2d 713 (Minn. 1986) (Rule 60.02 excluded divorce decrees; courts should not use Rule 60.02 to modify divorce decrees)
- Maranda v. Maranda, 449 N.W.2d 158 (Minn. 1989) (legislative amendment to § 518.145 provides mechanism for reopening dissolution decrees post-Lindsey)