Harriet Lansing

The case concerned a charge of reprisal discrimination brought by James Cannon against the Minneapolis Police Department after Cannon stated he would file a complaint about alleged racial discrimination during a 2006 incident at a towing facility where officers responded to a call. The Minnesota Commission on Civil Rights determined that the department had engaged in reprisal, awarded Cannon damages including $15,000 for mental anguish (which the commission doubled), imposed a civil penalty, and granted attorney fees. On appeal, the court affirmed the commission's finding of reprisal discrimination and its other rulings as supported by substantial evidence in the record, but modified the damages award because the applicable Minneapolis ordinance did not authorize multiplying mental-anguish damages. The court therefore reduced the mental-anguish award back to the original $15,000 amount while upholding the remainder of the judgment.

civil rightsprocedure

The case concerned a lease offer from Seafood House to Starlite that included a strict six-day acceptance deadline, after which the offer would be void, along with a guaranty from Landry’s; Starlite accepted five days late, Seafood House occupied the premises and paid rent for years, but later stopped paying, prompting Starlite to sue Landry’s under the guaranty. The district court granted summary judgment to Starlite, ruling that Seafood House had waived the deadline through its conduct. The appellate court reversed, concluding that Minnesota law does not permit the waiver doctrine to extend the time for acceptance during contract formation, as this differs from waiving performance terms in an existing contract, and remanded for consideration of other potential theories such as a counteroffer.

business & regulatoryproperty

This case involved a dispute over whether a receiver appointed during the foreclosure of a property owned by Kensington Equity Partners was obligated to pay Kensington's pre-existing delinquent utility bills to CenterPoint Energy. The district court granted summary judgment to the State Bank of Delano and the receiver, Swartz Brothers Associates, finding no such obligation, and the Court of Appeals affirmed. The court reasoned that under Minnesota's receivership statute for mortgaged property, a receiver must pay a mortgagor's debts only if they are necessary maintenance expenses or specifically required by the appointment order, and the past utility debt did not qualify as necessary for the property's continued operation since service was maintained without payment. Additionally, the receiver does not assume the mortgagor's contractual obligations or "step into its shoes" regarding pre-appointment debts.

propertyprocedurebusiness & regulatory

The case involved a teacher who had attained continuing-contract status in a Minnesota school district, resigned, taught elsewhere for a year, and was rehired by the same district; the district then treated him as subject to a new one-year probationary period under Minn. Stat. § 122A.40, subd. 5(a) and declined to renew his contract at the end of that year. The teacher appealed, arguing that he retained continuing-contract status and could only be terminated for cause. The court affirmed the district's decision, holding that the statute's plain language requires a one-year probationary period in each district where the teacher is thereafter employed, including a district where the teacher previously completed the initial three-year probationary period, and that the teacher's resignation had terminated his prior continuing contract.

labor & employment

This case involved a dispute over the duration of a father's child-support obligation after a Mississippi divorce decree was registered for enforcement and modification in Minnesota under the Uniform Interstate Family Support Act. The parties' youngest child had turned 20, at which point Minnesota law would treat the child as emancipated and end support, but Mississippi law would continue support until age 21. The district court denied the father's motion to terminate support, and the court of appeals affirmed that ruling. The core reasoning was that Minn. Stat. § 518C.611(c) prohibits a Minnesota tribunal from modifying any aspect of a child-support order, including its duration, that could not be modified under the law of the issuing state. The matter was remanded for consideration of the father's additional requests for relief unrelated to the duration issue.

family lawprocedure

In Freeman v. Swift, former executives of a nonprofit operating a juvenile treatment facility sued a local activist for defamation based on blog posts and an email criticizing their conduct during efforts to relocate the facility. The defendants moved to dismiss under Minnesota's anti-SLAPP statute, claiming immunity for speech aimed at procuring favorable government action in opposition to the project. The district court denied the motion, and the court of appeals affirmed, holding that the communications were not genuinely aimed at government bodies because they targeted a university dean and personal blog audiences instead. The core reasoning centered on the purpose, audience, and nature of the statements, which failed to qualify for statutory immunity regardless of other defenses.

free speechtorts & liabilityprocedure