The Court’s judgment and decree in a divorce cannot typically be reopened unless there is a finding of fraud. On motion and upon terms as are just, the Court may relieve a party from a judgment and decree, order or proceeding under Minn. Stat. 518.145, except for provisions dissolving the bonds of marriage, annulling the marriage, or directing that the parties are legally separated, and may order a new trial or grant other relief as may be just for the following reasons: (1) mistake, inadvertence, surprise, or excusable neglect; (2) newly discovered evidence which by due diligence could not have been discovered in time to move for a new trial under the Rules of Civil Procedure, rule 59.03; (3) fraud, whether denominated intrinsic or extrinsic, misrepresentation, or other misconduct of an adverse party; (4) the judgment or order is void; or (5) the judgment has been satisfied, released, or discharged, or a prior judgment and decree or order upon which it is based has been reversed or otherwise vacated, or it is no longer equitable that the judgment and decree or order should have prospective application. The motion must be made within a reasonable time, and for a reason under clause (1), (2), or (3). Minn. Stat. §518.145 (subd. 2); Minn. R. Civ. P. 60.02.
Although under Rule 60.02 of the Rules of Civil Procedure and Minn. Stat. §518.145 divorce decrees are specifically omitted from the provisions under which a party may be relieved from a final judgment, the Court has the inherent power to grant relief to a party who has been denied an opportunity to defend in a divorce action under such circumstances as to amount to fraud on the Court and the administration of justice. Bredemann v. Bredemann, 91 N.W. 2d 84, 85 (Minn. 1958). For there to be fraud on the Court and the administration of justice, there must be found to be fraud on defendant. Id. at 87. Absent fraud, as considered in the cases, the court has no authority to open up a divorce case. Id. This standard changes prior case law by holding that the other grounds for relief available under Rule 60.02, such as mistake, excusable neglect, or newly discovered evidence are no longer available grounds for relief in a dissolution action. Adams v. Adams, 393 N.W. 2d 508, 501 (Minn. App. 1986).
[F]raud on the Court must be an intentional course of material misrepresentation or non-disclosure, having the result of misleading the court and opposing counsel and making the property settlement grossly unfair. Maranda v. Maranda, 449 N.W. 2d 158, 165 (Minn. 1989). In Maranda, the Minnesota Supreme Court held that the husband committed fraud on the Court when he systematically excluded the wife from access to financial information, misrepresented facts about marital property, and concealed significant amounts of money, making it impossible for the district court to approve a fair settlement. Id. at 166.