Minnesota law provides a two-step analysis for awarding spousal maintenance. First, the district court determines that the spouse requesting that maintenance lacks sufficient property, or is otherwise unable to provide adequate self-support for her reasonable needs in light of the standard of living established during the marriage. In essence, the district court should award spousal maintenance when a party shows a sufficient and reasonable need.
In approaching the first step of the analysis, the district court has wide discretion in determining a party’s need for spousal maintenance. No single factor is dispositive, and the district court is afforded the discretion to weigh the facts of each case to determine whether maintenance is appropriate.
A district court performs the second step of the analysis to determine the duration and amount of the award of spousal maintenance after determining that the requesting spouse needs maintenance. It is the second step of this analysis that is referenced to in Subdivision 2 of Section 518.552. The factors listed in this section are:
(a) the financial resources of the party seeking maintenance, including marital property apportioned to the party, and the party’s ability to meet needs independently, including the extent to which a provision for support of a child living with the party includes a sum for that party as custodian;
(b) the time necessary to acquire sufficient education or training to enable the party seeking maintenance to find appropriate employment, and the probability, given the party’s age and skills, of completing education or training and becoming fully or partially self-supporting;
(c) the standard of living established during the marriage;
(d) the duration of the marriage and, in the case of a homemaker, the length of absence from employment and the extent to which any education, skills, or experience have become outmoded and earning capacity has become permanently diminished;
(e) the loss of earnings, seniority, retirement benefits, and other employment opportunities forgone by the spouse seeking spousal maintenance;
(f) the age, and the physical and emotional condition of the spouse seeking maintenance;
(g) the ability of the spouse from whom maintenance is sought to meet needs while meeting those of the spouse seeking maintenance; and
(h) the contribution of each party in the acquisition, preservation, depreciation, or appreciation in the amount or value of the marital property, as well as the contribution of a spouse as a homemaker or in furtherance of the other party’s employment or business.
In determining spousal maintenance the district court does not need to make findings regarding each factor. It is only necessary that the district court have considered each factor.
To affirm the order of a lower court, the higher court need only determine that the district court’s conclusions were logical and supported by the facts on the record. The “record” upon which the district court’s conclusions are to be based is not limited to the issues and facts before the district court on any given hearing date, but contains all the documents filed, all the exhibits filed, and all the proceedings held before the tribunal, and this is the same “record” which under review by the higher Court. Furthermore, the higher Court must look at the evidence “in the light most favorable” to the district court’s findings.
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