Justia Minnesota Supreme Court Opinion Summaries

Mark Juelich and Steven Thoemke, former employees of Toyota-Lift of Minnesota, Inc. (TLM), claimed that TLM failed to pay them commissions they earned under their employment agreements with TLM. Juelich and Thoemke sought penalties under Minn. Stat. 181.14. The district court determined that TLM owed additional commissions to Juelich and Thoemke totaling $104,000 and that TLM was entitled to recover $815,000 from American Warehouse Systems, LLC (AWS) due to AWS’s breach of an asset purchase agreement entered into by AWS and TLM and its unjust retention of customer payments owed to TLM. The district court denied the request of Juelich and Thoemke for penalties under section 181.14, reasoning that the $814,000 judgment owed to TLM from AWS offset the unpaid commissions owed to Juelich and Thoemke. The court of appeals reversed, concluding that TLM was liable for statutory penalties under section 181.14. The Supreme Court affirmed, holding that when a court determines whether an employer is liable to an employee for the statutory penalty for nonpayment of wages under section 181.14, the court may not consider offsetting liabilities owed by the employee to the employer. View "Toyota-Lift of Minnesota, Inc. v. American Warehouse Sys., LLC" on Justia Law

The Minnesota Department of Transportation (MnDOT) contracted with Mathy Construction Company for a public highway project. Mathy subcontracted with Storms, Inc. for excavation and fill work. After Storms completed its work, MnDOT issued a deductive change order reducing Mathy’s contract amount by $327,064 because of errors in the estimated quantities of excavation and fill required for Storms’ work. Mathy reduced Storms’ subcontract by the same amount. Storms subsequently sued Mathy for the reduction in the subcontract price. The district court granted summary judgment in favor of Storms, concluding that Mathy had breached the subcontract. The court of appeals affirmed. The Supreme Court reversed, holding that Mathy did not breach its subcontract with Storms by issuing a corresponding deductive change order to Storms. View "Storms, Inc. v. Mathy Constr. Co." on Justia Law

Appellant Patrick Figgins brought suit against respondent Grand Rapids State Bank (GRSB) and its CEO, respondent Noah Wilcox, claiming, among other things, that Wilcox and GRSB had made misrepresentations and breached an oral agreement regarding the due date of a payment on an outstanding loan. Respondents moved to dismiss on the ground that Minn. Stat. 513.33 (2014) did not permit these claims. The district court agreed and dismissed the complaint with prejudice. Figgins, on appeal, argued that section 513.33 did not apply to his claims and, to the extent it did, his promissory estoppel claim should have survived because promissory estoppel was an exception to the statute. Finding no reversible error in the district court's judgment, the Minnesota Supreme Court affirmed. View "Figgins vs. Wilcox" on Justia Law

At issue in this case was whether truck drivers hauling asphalt cement from a commercial oil refinery to a contractor’s facility are performing “work under a contract” under Minn. Stat. 177.44(1) and, therefore, must be paid prevailing wages. The Minnesota Department of Transportation (MDOT) determined that the construction companies that were awarded contracts to work on state highway projects violated the project contracts by failing to ensure that drivers that assisted in the acquisition and transport of asphalt cement for the projects were paid prevailing wages. Appellants argued that the hauling activities of these drivers did not constitute “work under a contract” under Minn. Stat. 177.44(1) and, alternatively, that the hauling activities were exempt from the prevailing wage requirements under the “commercial establishment exception” in the Prevailing Wage Act. The district courts granted summary judgment to MDOT. The court of appeals affirmed. The Supreme Court reversed, holding that hauling activities must be to, from, or on the site of a public works project to qualify as “work under a contract,” and therefore, the hauling activities in this case did not constitute “work under the contract” subject to the prevailing wage requirements. View "J.D. Donovan, Inc. v. Minn. Dep’t of Transp." on Justia Law

Appellants’ homeowners insurance policy with State Farm Fire and Casualty Company provided that State Farm will be only the “actual cash value” at the time of the loss of damaged property. Appellants brought a putative class action lawsuit against State Farm, claiming that State Farm breached the terms of Appellants’ policy when it calculated the actual cash value of damaged property. Specifically, Appellants alleged that State Farm’s practice of depreciating embedded labor costs breached State Farm’s duty to indemnify the insured for the actual cash value of the damaged property. The district court certified a question regarding the issue to the Supreme Court. The Court answered that, absent specific language in the insurance policy that identifies the method of calculating actual cash value, the trier of fact may consider, among many other factors, embedded-labor-cost depreciation when such evidence logically tends to establish the actual cash value of a covered loss. View "Wilcox v. State Farm Fire & Cas. Co." on Justia Law

The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law

Appellant represented a client pursuant to a contingent-fee agreement but voluntarily withdrew from the representation of the client when efforts to settle the case failed. The client subsequently retained substitute counsel, and substitute counsel successfully negotiated a settlement. Appellant filed suit seeking to recover in quantum meruit the value of the services provided prior to withdrawal. The district court entered judgment against Appellant, concluding that Appellant was not entitled to recover in quantum meruit because he failed to establish good cause for withdrawal. The Supreme Court affirmed, holding (1) an attorney may withdraw from a contingent-fee agreement with or without cause, provided that the withdrawal satisfies the rule of professional responsibility; (2) the attorney may recover in quantum meruit the reasonable value of the services rendered prior to withdrawal if the attorney establishes that the withdrawal is for good cause; and (3) Appellant in this case failed to establish good cause. View "In re Petition for Distribution of Attorney’s Fees between Stowman Law Firm, P.A., and Lori Peterson Law Firm" 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

Sysdyne Corporation and Xigent Solutions, LLC provide staff augmentation services to companies in the engineering and information industries. When Brian Rousslang, a former employee of Sysdyne Corporation who was subject to a noncompete agreement, obtained employment with Xigent Solutions, LLC, Sysdyne sued Xigent for tortious interference with contract and sued Rousslang for breach of contract. The trial court (1) awarded damages to Sysdyne on its breach of contract claim with respect to certain preexisting customers Rousslang brought with him from Sysdyne to Xigent; but (2) ruled in favor of Xigent on the tortious interference claim, concluding that Xigent was justified in interfering with the contract because Xigent conducted a reasonable inquiry into the enforceability of the noncompete agreement and, based on advice of outside counsel, honestly believed that the agreement was unenforceable. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the justification defense to a claim of tortious interference with a contract may be satisfied by a defendant’s reliance on incorrect advice of outside counsel; and (2) under the facts of this case, the trial court did not err in concluding that Xigent met its burden of proving the justification defense. View "Sysdyne Corp. v. Rousslang" on Justia Law

This case stemmed from the largely fraudulent lending operations of First United Funding, LLC (First United). After First United collapsed, a court-appointed Receiver commenced this action under Minnesota’s Uniform Fraudulent Transfer Act (MUFTA) against several financial institutions, including Alliance Bank and certain Respondent Banks, that had participated in First United’s loan-participation scheme. The district court (1) dismissed the claims against the Respondent Banks for failure to bring the action in a timely fashion, and (2) allowed the claim against Alliance Bank, concluding that that the Receiver had pleaded legally sufficient claims based on a “Ponzi-scheme presumption.” The district court then entered judgment against Alliance Bank. The Receiver and Alliance Bank appealed. The court of appeals (1) divided the Ponzi-scheme presumption into three separate components and concluded that the third component was unfounded in the case of Alliance Bank; and (2) concluded that the district court erred when it dismissed the Receiver’s actual-fraud claims against the Respondent Banks. The Supreme Court affirmed as modified, holding (1) all three components of the Ponzi-scheme presumption lack support in MUFTA; and (2) the Receiver failed to adequately plead constructive fraud, but the district court erred when it dismissed the Receiver’s actual fraud claims. Remanded. View "Finn v. Alliance Bank" on Justia Law