Marriage of Frauenshuh v. Giese

GILBERT, Justice

(dissenting).

I respectfully dissent from the majority opinion, which sets aside a 5-year-old court approved custody stipulation. I cannot concur with this decision because of the inequities that result with respect to both the parents and their child.

Although courts are not strictly bound by stipulations between litigating parties, stipulations are heavily favored in dissolution and custody proceedings. “Courts favor stipulations in dissolution cases as a means of simplifying and expediting litigation, and to bring resolution to what frequently has become an acrimonious relationship between the parties.” Shirk v. Shirk, 561 N.W.2d 519, 521 (Minn.1997). “Custody provisions contained in a stipulated decree must be accorded a good deal of deference, in that they represent the terms specifically agreed to by the parties and adopted by the court.” Ayers v. Ayers, 508 N.W.2d 515, 520 (Minn.1993). Similarly, the General Rules of Practice for the District Courts encourage, and in certain instances mandate, alternative dispute resolution in family cases. See Minn. R. Gen. Prac. 310.01. While the majority opinion pays lip service to this precedent, it nevertheless entirely disregards the stipulation entered into between the parents in the present case.

As part of their Marital Termination Agreement (MTA), Frauenshuh and Giese agreed on the importance of providing their child with a stable community environment. To that end, they entered into a stipulation to ensure that their child would not be taken out of his community environment unless such a move was consistent *160with the best interests of the child. The majority now holds this stipulation invalid, reasoning that Minn.Stat. § 518.18(d)(iii) precludes parties without joint physical custody from seeking modification of a custody order unless the child is endangered. The majority relies on several canons of statutory interpretation to support its assertion that the legislature intended the endangerment standard set forth in section 518(d)(iii) to apply in all cases where one parent has been granted sole physical custody. In so doing, however, the majority ignores the equities of this case and the findings of the trial court.

The majority’s opinion undermines Frauenshuh’s and Giese’s well-settled rights and expectations. Frauenshuh and Giese stipulated to certain dissolution and custody conditions. If any of those stipulations were not in the best interest of the child, the trial court should have rejected them when the couple’s MTA was originally presented to the court. The trial court did not do this. Rather, the court read and approved the dissolution stipulation and incorporated the terms thereof into its judgment and dissolution decree. Neither party appealed from that judgment and decree. Now, approximately 5 years after the finalization of the trial court’s judgment, the majority is changing the rules for this family. What the parties believed and the trial court declared to be a legally binding condition on Giese’s physical custody, the majority now declares to be invalid. In so doing, the majority is effectively, and somewhat paradoxically, permitting Giese to unilaterally modify and eliminate an express condition of the original custody order.

Most troubling about this unilateral amendment of the original custody order is that it fails to incorporate, and may in fact violate, the best interests of the parties’ minor child. The majority correctly recognizes that in child custody matters, “the paramount consideration is the welfare and best interests of the children.” See also Petersen v. Petersen, 296 Minn. 147, 148, 206 N.W.2d 658, 659 (1973). As the facts of the present case demonstrate, however, the majority’s narrow interpretation and strict application of section 518.18 undermine this standard.

The stipulation entered into by Frauen-shuh and Giese provided that, in the event either parent moved more than 50 miles, custody would be determined by looking to the best interests of the child. Thus, the parties sought to apply the very standard the majority purports to protect Upon review of the facts of this case, the trial court ruled that it was in the best interests of the child to remain in Ortonville and, to that end, ordered that Frauenshuh be granted physical custody of the child. The majority, however, now elevates a boilerplate standard designed to promote permanency and closure in child custody matters ahead of what has been determined to be in the best interests of the child in this particular case. Thus, the majority opinion renders the best interests of the child irrelevant.

Importantly, Frauenshuh and Giese did not try and circumvent statutory provisions designed to protect children. Rather, they agreed that, in the event one of the parties made a move disruptive to their child’s community environment, their child’s interest should be given even greater protection than the law requires. Nevertheless, the majority now refuses to apply the best interests standard, and instead applies the endangerment standard set forth in Minn.Stat. § 518.18(d)(iii). In so doing, the majority denies the parents the right to determine what factors are most important to the well being of their child and thus most deserving of the highest level of protection the law can provide. At a time when parents should be applauded for placing their child’s interests above their own in dissolution and post-dissolution proceedings, the majority’s opinion serves only to thrust the courts *161even more into micromanaging family relationships. Accordingly, I would affirm the court of appeals.