Justia Minnesota Supreme Court Opinion SummariesArticles Posted in Civil Procedure
DeCook v. Olmsted Med. Ctr., Inc.
Plaintiffs filed suit against Defendants for medical malpractice. Defendants moved to dismiss the complaint for insufficient process and and insufficient service of process. The district court (1) denied the motions to dismiss for insufficient process, concluding that, although the summons and complaint were defective due to the lack of a Minnesota attorney’s signature, the Minnesota Rules of Civil Procedure granted the court discretion to allow the summons and complaint to be cured by amendment; and (2) denied the motions to dismiss for insufficient service of process as to some defendants, finding those defendants to have been validly served, but granted the motions with respect to the remaining defendants. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the summons and complaint bearing only the signature of an attorney not licensed to practice in Minnesota were defective, but the district court did not abuse its discretion in allowing them to be amended; and (2) Plaintiffs in this case produced sufficient evidence of effective service, and Defendants did not satisfy their burden to prove that service was not effective, and therefore, the district court erred in granting Defendants’ motion to dismiss for insufficient service. View "DeCook v. Olmsted Med. Ctr., Inc." on Justia Law
Contractors Edge, Inc. v. City of Mankato
This case arose from a dispute over a construction contract entered into between Contractors Edge, Inc. and the City of Mankato. Contractors Edge sued the City alleging, as relevant to this appeal, breach of contract and violation of the Prompt Payment Act. The district court dismissed the breach of contract claim in an order (the October 2012 order) that concluded, “let judgment be entered accordingly.” Neither party asked for a certification of final judgment under Minn. R. Civ. P. 54.02. The parties subsequently settled the remaining Prompt Payment Act claim. The district court entered final judgment in January 2014. Contractors Edge appealed, challenging the October 2012 order. The court of appeals dismissed the appeal as time barred, holding (1) regardless of whether the district court properly certified the October 2012 order, the partial judgment was immediately appealable, and (2) Contractors Edge’s appeal time had expired. The Supreme Court reversed, holding (1) the district court abused its discretion in certifying the October 2012 order as a final partial judgment under Rule 54.02; and (2) when a district court abuses the discretion given in Rule 54.02 to certify an order as a final partial judgment, the resulting judgment is not final and is not immediately appealable. View "Contractors Edge, Inc. v. City of Mankato" on Justia Law
Walsh v. U.S. Bank, N.A.
The question presented in this case was whether the plausibility standard announced in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal applies to civil pleadings in Minnesota state court. Defendant in this case moved to dismiss Plaintiff’s complaint pursuant to Minn. R. Civ. P. 12.02(e) for failure to state a claim upon which relief can be granted, alleging that the complaint failed to allege enough facts to state a plausible claim. Using the Twombly plausibility standard, the district court dismissed Plaintiff’s complaint with prejudice, concluding that Plaintiff failed to establish facts giving rise to a plausible claim for relief. The court of appeals reversed after applying the state’s traditional pleading standard. The Supreme Court affirmed, holding (1) the Twombly plausibility standard does not govern civil pleadings in Minnesota; and (2) Plaintiff’s complaint satisfies the traditional pleading standard for civil actions in Minnesota. View "Walsh v. U.S. Bank, N.A." on Justia Law
Posted in: Civil Procedure