Justia Minnesota Supreme Court Opinion Summaries

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

In 2012, the governing board of Avera Marshall Regional Medical Center notified the hospital’s medical staff that it had approved the repeal of the medical staff bylaws and replaced them with revised bylaws. Avera Marshall’s Medical Staff, Chief of Staff, and Chief of Staff-elect commenced an action seeking a declaration that the Medical Staff had standing to sue Avera Marshall and that the former medical staff bylaws constituted a contract between Avera Marshall and the Medical Staff. The district court granted judgment for Avera Marshall and dismissed the case, concluding that the Medical Staff lacked the capacity to sue under Minnesota law and that the medical staff bylaws did not constitute an enforceable contract between Avera Marshall and the Medical Staff. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Medical Staff has the capacity to sue and be sued under Minnesota law; and (2) the medical staff bylaws constitute an enforceable contract between Avera Marshall and the individual members of the Medical Staff. Remanded. View "Medical Staff of Avera Marshall Reg’l Med. Ctr. v. Avera Marshall" on Justia Law

An Insurer issued a life insurance policy to an Insured. After the Insured died, the Insurer refused to pay the death benefit to Plaintiff, the Insured’s widow, and rescinded the life insurance policy based on its discovery that the Insured had failed to disclose that he had undergone certain medical procedures. Plaintiff sued the Insurer and the medical records contractor from whom the Insurer requested the Insured’s medical records. The district court granted summary judgment to Defendants, concluding (1) the Insured’s failure to disclose the medical procedures made his statements willfully false or intentionally misleading as a matter of law; and (2) a patient does not have a cause of action under Minn. Stat. 144.298(2) for withholding a medical record that the patient authorized to be released. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) rescission of a life insurance policy requires proof of the insured’s subjective intent to deceive, and there was a genuine issue of material fact regarding the intent of the Insured in this case; and (2) a patient does not have a private right of action under section 144.298(2) when a person releases fewer medical records than authorized by a patient’s consent. View "Larson v. Northwestern Mut. Life Ins. Co." on Justia Law

After Sining Mao left his employment with Seagate Technology, LLC, Mao joined Seagate’s competitor, Western Digital Corporation. Seagate subsequently commenced a district court action alleging that Mao stole Seagate’s trade secrets and confidential information and provided it to Western Digital. Western Digital invoked an arbitration clause in Mao’s employment agreement with Seagate. Before the arbitration hearing, Seagate brought a motion for sanctions against Western Digital and Mao (Appellants) based on alleged fabrication of evidence. An arbitrator issued an award against Appellants in an amount exceeding $500 million. The district court vacated the award in part, but the court of appeals reinstated the award. On appeal, Appellants argued that the arbitrator’s exceeded his authority by issuing punitive sanctions and prejudiced Appellants by refusing to hear evidence material to the controversy. The Supreme Court affirmed the court of appeals’ decision reinstating and confirming the arbitration award in full, holding that the arbitrator did not exceed his authority or refuse to hear material evidence as required for vacatur. View "Seagate Tech., LLC v. W. Digital Corp." on Justia Law

Lyon filed a breach of contract action against Illinois Paper in federal district court, alleging that Illinois Paper had breached a contractual representation and warranty that all lease transactions presented to Lyon for review would be "valid and fully enforceable agreements." The Seventh Circuit certified questions to the court under Minn. Stat. 480.065. The court reformulated the questions and held that a claim for breach of a contractual representation of future legal compliance is actionable under Minnesota law without proof of reliance. View "Lyon Financial Services, Inc. v. Illinois Paper and Copier Co." on Justia Law

The Minnesota Laborers Health and Welfare Fund (“the Funds”) filed a declaratory judgment action against Granite Re, Inc. seeking clarification of their right to payment on a surety bond. The district court granted summary judgment to Granite Re, concluding, among other things, that the Funds’ lawsuit was time-barred because the Funds failed to commence litigation within the one-year contractual limitations period set out in the bond. The court of appeals reversed and remanded, concluding that fraudulent concealment by the bond principal tolled the limitations period set out in the bond. The Supreme Court affirmed, holding (1) fraudulent concealment can be applied to a surety that was not involved in the fraudulent concealment by the principal; and (2) therefore, the one-year contractual limitations period set out in the bond may be tolled against Granite Re. View "Minn. Laborers Health & Welfare Fund v. Granite Re, Inc." on Justia Law