Mohrman, Kaardal & Erickson, P. A., f/k/a Mohrman & Kaardal, P. A. v. Gene Rechtzigel, Gene Rechtzigel as Personal Representative for Estate of Frank H. Rechtzigel and as Trustee of any Trust thereunder, A15-1886

Mohrman, Kaardal & Erickson (respondent) obtained summary-judgment money judgments against Gene Rechtzigel (appellant) in May 2014 for unpaid attorney fees; appeals and petitions for review were denied.
Respondent served post-judgment discovery on Rechtzigel (Jan 2015) seeking full disclosure of assets to aid collection; Rechtzigel did not timely comply.
The district court granted respondent’s motion to compel (May 11, 2015) and later found Rechtzigel in contempt for failing to respond (Aug 20, 2015); $1,500 in fees were awarded in connection with the discovery motion and contempt enforcement.
Rechtzigel served objections asserting the Fifth Amendment after the contempt order and did not substantiate how responses would be incriminating; respondent moved to enforce the contempt order.
After an order-to-show-cause hearing, the district court entered a final civil-contempt order (Oct 21, 2015) authorizing up to 180 days incarceration with purge options (producing discovery, posting bond/cashier’s check or satisfying the judgment).
Rechtzigel appealed solely the contempt proceedings; the district court later recorded that he posted funds to purge the contempt and the funds were released to satisfy the judgments.

Issue	Plaintiff's Argument (Mohrman)	Defendant's Argument (Rechtzigel)	Held
Subject-matter jurisdiction for post-judgment discovery	District court had jurisdiction to compel post-judgment discovery to aid enforcement of its money judgment	Post-judgment discovery was void because it was served before judgments were docketed; court lacked jurisdiction	Court: district court had jurisdiction; serving discovery pre-docketing did not void discovery; rejection of jurisdiction challenge
Validity of Fifth Amendment objections to discovery	Discovery seeks only financial records/assets; no real danger of criminal self-incrimination	Invoked Fifth Amendment generally to avoid producing discovery	Court: blanket Fifth Amendment assertion was insufficient; no showing responses would tend to incriminate; contempt finding sustained
Use of contempt (civil) vs. execution or criminal punishment	Contempt is appropriate civil remedy to compel discovery; purge clause makes sanction civil	Contempt amounted to imprisonment for debt or criminal contempt	Court: sanction was civil (prospective, purge conditions); contempt was appropriate to secure compliance
Attorney-fee awards tied to discovery/contempt	Fees reasonably incurred for motion to compel and enforcement; permitted under Minn. R. Civ. P. 37 and Minn. Stat. § 588.11	Fees excessive/abuse of discretion	Court: awarded $750 for motion to compel and $750 under contempt statute were reasonable and not punitive; no abuse of discretion

Mower Cty. Human Servs. v. Swancutt, 551 N.W.2d 219 (Minn. 1996) (lists minimum requirements for civil contempt and explains purge-clause significance)
Parker v. Hennepin Cty. Dist. Court, 285 N.W.2d 81 (Minn. 1979) (Fifth Amendment in civil cases must be tied to reasonable fear of criminal incrimination)
Prod. Credit Ass’n of Redwood Falls v. Good, 228 N.W.2d 574 (Minn. 1975) (court determines whether privilege applies; witness’s conclusory claim is insufficient)
Erickson v. Erickson, 385 N.W.2d 301 (Minn. 1986) (purpose of contempt power is to enforce court orders; contempt is an inherent judicial power)
Hanson v. Thom, 636 N.W.2d 591 (Minn. App. 2001) (factors for attorney-fee awards under contempt statute require proof of actual damages, non-penal award, and that fees were incurred)