Justia Minnesota Supreme Court Opinion Summaries

Respondent brought a civil suit against Appellant. After Respondent transmitted the summons, complaint, and affidavit of service, Appellant filed a motion to dismiss on the grounds that Respondent failed to timely file. Respondent filed a motion to vacate under Minn. R. Civ. P. 60.02, arguing that his counsel’s admitted neglect in timely filing was excusable because of counsel’s ignorance of the law. The district court dismissed the action, concluding that ignorance of the law by Respondent’s counsel was not excusable neglect under Rule 60.02. The court of appeals reversed. The Supreme Court affirmed as modified, holding that the district court abused its discretion by failing to consider all four requirements from Finden v. Klaas. Remanded to the district court for reconsideration of Respondent’s Rule 60.02 motion. View "Cole v. Wutzke" on Justia Law

Respondents filed a class-action complaint alleging, among other claims, that MoneyMutual, LLC, which operates a website allowing individuals to apply for short-term loans known as payday loans, matched Respondents with payday lenders that were unlicensed in Minnesota and that the terms of the payday loans were illegal. MoneyMutual moved to dismiss the complaint for lack of personal jurisdiction. The district court denied the motion to dismiss, concluding that it could exercise specific personal jurisdiction over MoneyMutual based on MoneyMutual’s email correspondence with residents and advertising in Minnesota. The court of appeals affirmed. The Supreme Court affirmed, holding that sufficient minimum contacts existed for the exercise of personal jurisdiction over MoneyMutual and that exercising personal jurisdiction over MoneyMutual comported with notions of fair play and substantial justice. View "Rilley v. MoneyMutual, LLC" on Justia Law

Whitney National Bank (Whitney) obtained a judgment against Daniel Fitzpatrick and his business entities (collectively, Fitzpatrick). In a separate matter, Fitzpatrick, represented by O’Brien & Wolf, LLP, obtained a judgment against the City of Oronoco. Whitney served a garnishment summons on the City to establish and perfect a garnishment lien against the judgment proceeds won by Fitzpatrick. O’Brien subsequently filed a motion to establish and determine the amount and priority of its attorney’s lien. The district court held that Whitney’s garnishment lien was superior to O’Brien’s attorney’s lien, concluding that a cause-of-action attorney’s lien is perfected, as against third parties, from the time the attorney files notice of the lien claim. The court of appeals reversed. The Supreme Court affirmed, holding that the plain language of Minn. Stat. 481.13(1)(a)(1) does not require an attorney with a cause-of-action attorney’s lien to file notice of the lien claim for the lien to have priority over third-party claims. View "City of Oronoco v. Fitzpatrick Real Estate, LLC" on Justia Law

The City of Vadnais Heights imposed an assessment on real property owned by McCullough and Songs, Inc. McCullough appealed the City’s decision. The City moved for summary judgment, arguing that McCullough was precluded from appealing because it had failed to file a written objection to the proposed assessment. The district court denied the motion. The court of appeals reversed, concluding that a party opposed to a proposed amendment must object in writing before or at the assessment hearing to preserve its right to appeal the assessment to the district court. McCullough appealed. The Supreme Court dismissed the appeal, vacated the court of appeals’ decision, and remanded, holding that the court of appeals lacked jurisdiction to review the order denying summary judgment to the City. View "McCullough & Sons, Inc. v. City of Vadnais Heights" on Justia Law

Respondent filed suit against appellant for personal injuries he suffered as a result of an automobile accident. Respondent attempted to serve the summons and complaint on appellant via certified mail. The district court concluded that appellant was not properly served before the statute of limitations expired and therefore dismissed the complaint. The court of appeals reversed and remanded. The court held that service of process via certified mail does not constitute personal service under Minn. R. Civ. P. 4.03. Accordingly, the court reversed the court of appeals' decision and reinstated the district court's judgment of dismissal with prejudice. View "Melillo v Heitland" on Justia Law

Kelly Dennis was allegedly injured in the course of his employment with The Salvation Army. Dennis filed a claim for workers’ compensation benefits, but The Salvation Army and its insurer (collectively, Relators) denied liability. The compensation judge awarded Dennis benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed. Within thirty days, Relators filed a petition for a writ of certiorari with the clerk of the appellate courts. Relators, however, failed to serve a cost bond on the WCCA as required by Minn. Stat. 176.471. Relators subsequently served an untimely cost bond on the WCCA. At issue before the Supreme Court was whether timely service of the cost bond was mandatory to have the WCCA order reviewed by the Supreme Court on certiorari. The Supreme Court discharged the writ of certiorari and dismissed the appeal, holding that Relators’ failure to file the cost bond within the thirty-day period to appeal was fatal to their appeal. View "Dennis v. Salvation Army" on Justia Law

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

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

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

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