Justia Civil Procedure Opinion Summaries

The Minnesota Supreme Court ruled that an individual can bring a private action under the Minnesota private attorney general statute to compel a healthcare provider to disclose that individual’s medical records as required by the Minnesota Health Records Act. This decision was based on the interpretation of the private attorney general statute, which the court concluded applies to laws regarding unfair, discriminatory, and other unlawful practices in business, commerce, or trade. The court found that the Minnesota Health Records Act, which mandates the timely disclosure of health records to patients, falls within this category. However, the court also held that an individual does not have a private right of action under the Minnesota Health Care Bill of Rights to compel a healthcare provider to disclose an individual’s medical records. The ruling affirmed in part, reversed in part, and remanded the case to the district court for further proceedings. View "Findling vs. Group Health Plan, Inc." on Justia Law

In this case stemming from a dispute involving an insurance claim the Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court dismissing, with prejudice, Plaintiff's complaint under Minn. R. Civ. P. 5.04(a) on the grounds that the complaint was not filed within one year of service, holding that Plaintiff satisfied Rule 5.04(a).Plaintiff served Defendant with a summons and complaint but did not file the summons and complaint with the district court at that time. Later, Plaintiff filed a copy of the summons and complaint but did not file the summons and complaint as a standalone document until more than one year after it had served Defendant. The district court dismissed the case with prejudice under Rule 5.04(a). The court of appeals reversed. The Supreme Court affirmed, holding (1) filing an "action" under Rule 5.04(a) refers to filing the summons and complaint; and (2) Plaintiff satisfied Rule 5.04(a) when it filed a copy of the summons and complaint as an exhibit in an ancillary motion pertaining to the same action. View "Glen Edin of Edinburgh Ass'n v. Hiscox Insurance Co." on Justia Law

The Supreme Court reversed the decision of the workers' compensation court of appeals (WCCA) affirming the decision of the compensation judge granting Respondent's claim petition seeking reimbursement from his former employer for the cost of medical cannabis, holding that the WCCA erred.At issue before the Supreme Court was whether the WCCA correctly concluded that it lacked subject matter jurisdiction to decide arguments that require interpreting federal law and whether the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, preempts the requirement in Minnesota law for an employer to reimburse an injured employee for the cost of medical treatment, Minn. Stat. 176.135, subd. 1(a). The Supreme Court held (1) the WCCA lacked subject matter jurisdiction to decide whether the relevant federal law preempted the relevant Minnesota law in this case; and (2) the CSA preempted the compensation court's order mandating Relators to pay for Respondent's medical cannabis. View "Bierbach v. Digger's Polaris" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying the City of Saint Paul's motion to discharge Respondent's petition for a writ of certiorari on the basis that Respondent failed to serve the petition on the agency, as required by Minn. Stat. 14.64, within the thirty-day deadline set forth in Minn. Stat. 14.63, holding that the thirty-day deadline in section 14.63 does not apply to the service requirement imposed by section 14.64.Respondent sought relocation benefits under the Minnesota Uniform Relocation Act after its lease of a bowling alley was prematurely terminated due to construction. The City denied the request, and an administrative law judge denied Respondent's claim. Respondent filed a petition for a writ of certiorari and served the petition on the City within thirty days of receiving the decision. The City sought to discharge the writ and dismiss the appeal based on untimely service. The court of appeals denied relief. The Supreme Court affirmed, holding that judicial review under the Administrative Procedure Act is invoked by compliance with the provisions of section 14.63, and the thirty-day deadline in section 14.63 does not apply to the service requirement imposed by section 14.64. View "In re Midway Pro Bowl Relocation Benefits Claim" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's exercise of specific personal jurisdiction over Ford Motor Company in this products liability case, holding that the claims in this case arose out of or related to Ford's contacts with Minnesota, and therefore, the exercise of specific personal jurisdiction by the Minnesota court was proper.A Ford vehicle owned by a Minnesota resident was involved in a car crash in which an airbag in the vehicle failed to deploy and a passenger was seriously injured. Ford moved to dismiss the passenger's claims for lack of personal jurisdiction, arguing that because the car involved in the accident was not designed, manufactured, or originally sold in Minnesota, Ford could not be subject to personal jurisdiction in Minnesota. The district court held that the exercise of jurisdiction over Ford was proper, and the court of appeals affirmed. The Supreme Court affirmed, holding that Ford's contacts with Minnesota were sufficient to support specific personal jurisdiction and that the reasonableness factors did not detract from the reasonableness of asserting jurisdiction over Ford in this case. View "Bandemer v. Ford Motor Co." on Justia Law

The Supreme Court discharged the writ of certiorari sought by Guardian Energy and dismissed the appeal in this case, holding that the order appealed from was not a final order at the time Guardian petitioned for a writ of certiorari, and therefore, this Court lacked jurisdiction.In 2015, the Supreme Court remanded this case to the tax court, concluding that the tax court's external-obsolescence calculations in valuating Guardian's property were not reasonably supported by the records. Before judgment was entered on the tax court's new order entered in 2016, Waseca County filed a motion requesting correction of computational errors made by the tax court through amended findings. Thereafter, the tax court stayed entry of judgment. Before the tax court ruled on the County's motion, Guardian sought review of the tax court's order. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the County's unresolved motion and the tax court's stay of entry of judgment rendered the 2016 order not final. Therefore, this Court lacked jurisdiction over Guardian's appeal. View "Guardian Energy, LLC, Relator v. County of Waseca" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court that concluded that a fee agreement between the parties was not void and thus ordering arbitration, holding that the district court erred by directing entry of final judgment rather than staying the proceedings, and therefore, there was no proper final judgment from which to take an appeal.Plaintiffs sued Defendants after learning that Defendants had provided brokerage services to Plaintiffs without the requisite state license. Specifically, Plaintiffs alleged that the fee agreement obligating Defendants to pay for the services provided was void as against public policy. Defendants, in turn, moved to compel arbitration pursuant to the terms of the fee agreement and to dismiss or to stay the underlying proceedings. The district court ordered arbitration and dismissed the case, concluding that the fee agreement was not void. The court of appeals reversed, determining that the fee agreement was void. The Supreme Court vacated the court of appeals’ decision, holding that the district court erred by dismissing the case instead of staying proceedings and that the court of appeals erred when it concluded that it had jurisdiction over the merits of this case. View "Woischke v. Stursberg & Fine, Inc." on Justia Law

State law did not preempt a proposal to amend the charter of the City of Bloomington to require voter approval before the City can implement organized collection of solid waste.Appellants petitioned the City for a ballot initiative seeking the enactment of an ordinance that would require voter approval before the City could implement organized waste collection. The City declined to place Appellants’ proposed amendment on a ballot on the ground that Minn. Stat. 115A.94 preempted the field of regulation by the process by which a city organizes waste collection. The district court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court reversed, holding (1) the legislature did not intend to occupy the field of regulation of the process of organizing collection of solid waste; and (2) therefore, Appellants’ proposed charter amendment was not preempted by state law. View "Jennissen v. City of Bloomington" on Justia Law

A facsimile transmission is not a “delivery” under Minn. R. Civ. P. 3.01(c), which requires that a summons be “delivered” to the sheriff before an action is commenced, because Rule 3.01(c) contemplates personal delivery to the office of the sheriff.In this case, Plaintiff faxed a summons and complaint to the sheriffs in two counties. Deputy sheriffs from both counties personally served Defendants. Defendants moved to dismiss the action, arguing that facsimile transmission did not constitute “delivery” of the summons under Rule 3.01(c). The district court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding that the sheriffs completed service of process on each of the defendants, thus commencing Plaintiff’s action under Rule 3.01(a). View "Cox v. Mid-Minnesota Mutual Insurance Co." on Justia Law

Applying Minn. R. Civ. P. 6.02 to extend the lis pendens deadline in Minn. Stat. 582.043(7)(b) is prohibited because to do so would impermissibly modify the substantive rights provided by the statute.The Supreme Court answered in the negative a question certified to it by the United States Court of Appeals for the Eighth Circuit as to whether the lis pendens deadline may be extended upon a showing of excusable neglect under Rule 6.02. At issue was whether the lis pendens recording requirement was procedural or substantive in nature. The Supreme Court held that to extend the lis pendens deadline using Rule 6.02 would be an impermissible intrusion into matters of substantive law. View "Litterer v. Rushmore Loan Management Services, LLC" on Justia Law