Smith v. Erickson, 923 N.W.2d 503

Parents of a child born in 2014; Smith (self-represented) sued in Nov. 2015 over custody, decision-making, and support; initial judgment entered Jan. 8, 2016.
From Jan. 2016–Apr. 2018 the docket shows over 400 entries, mostly filings by Smith, including multiple contempt motions and repeated communications to court personnel.
A referee recommended, and the district court adopted, awarding Erickson primary residential responsibility and sole decision-making for the child (Jan. 2018).
District court found Smith in contempt for nonpayment of child support (Feb. 28, 2018) based on arrears and its finding he was capable of full-time employment.
District court declared Smith a vexatious litigant and entered a pre-filing order requiring leave of court before Smith may file new documents (Apr. 23, 2018).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Contempt for nonpayment of child support	Smith said inability (lack of employment) made nonpayment excusable; he missed only one payment	Court/Erickson relied on records showing ~20 months arrears and ability to work	Affirmed: district court did not abuse discretion; Smith failed to prove inability to comply
Award of sole medical/mental-health decision-making	Smith argued referee’s findings insufficient to support sole authority	Erickson argued findings and proceedings supported award	Not reviewed on merits: appeal precluded by Smith’s failure to order/ provide transcripts
Failure to obtain transcript fee waiver	Smith sought waiver as indigent	Court denied: fee waivers limited to criminal/fundamental-right contexts	Denied: lack of transcript precludes meaningful appellate review of some issues
Vexatious litigant/pre-filing restriction	Smith argued restriction violated constitutional right of access to courts	Court cited repeated, frivolous filings that burdened parties and court resources; pre-filing order preserves reasonable access	Affirmed: district court did not abuse discretion in declaring Smith vexatious and imposing leave requirement

Montgomery v. Montgomery, 667 N.W.2d 611 (2003) (standard and burden for civil contempt)
Peterson v. Peterson, 883 N.W.2d 449 (2016) (abuse-of-discretion review in contempt and compliance defenses)
Solwey v. Solwey, 908 N.W.2d 690 (2018) (appellate consequence of failing to order transcripts for evidentiary hearings)
In the Matter of Emelia Hirsch, 904 N.W.2d 740 (2017) (abuse-of-discretion review for vexatious-litigant determinations)
Federal Land Bank of St. Paul v. Ziebarth, 520 N.W.2d 51 (1994) (constitutional right of access to courts may be limited by public interest and necessities)