A pending Minnesota Supreme Court case could reshape when out-of-state businesses can be sued in Minnesota based on contracts they never signed.

The Minnesota Supreme Court’s decision to grant review in Medtronic, Inc. v. Lahn highlights an unsettled issue in personal jurisdiction: How far can courts extend their reach by binding non-signatories to forum selection clauses under the “closely related” doctrine?

At stake is not just the application of the doctrine in a single case, but the broader question of how expansively courts may exercise personal jurisdiction over out-of-state parties.

Continue Reading When Is “Close” Close Enough? Minnesota Supreme Court to Review Scope of the “Closely Related” Personal Jurisdiction Doctrine

In Jennissen v. City of Bloomington, 913 N.W.2d 456 (2018), the Minnesota Supreme Court recently held that Minn. Stat. § 115A.94 (2016) does not preempt local ordinances concerning municipal waste collection systems, finding that the Legislature did not intend to occupy the field but instead left room for supplemental municipal regulation.  In reversing decisions by the Hennepin County District Court and the Minnesota Court of Appeals, the Minnesota Supreme Court specifically found that Minn. Stat. § 115A.94 does not preempt Bloomington residents’ passage of a charter amendment that would prevent the City of Bloomington from implementing an organized waste collection ordinance without prior voter approval. On remand, the Court of Appeals held that the residents’ proposed charter amendment was an improper referendum.  The Minnesota Supreme Court granted review on January 15, 2019.

Continue Reading In Reversal, Minnesota Supreme Court Finds State Law Does Not Preempt Proposed City Charter Amendment On Municipal Waste Collection System

The Minnesota Supreme Court recently clarified the application of the doctrine against disproportionate forfeiture under Minnesota contract law in Capistrant v. Lifetouch Nat’l Sch. Studios, Inc., 916 N.W.2d 23 (Minn. 2018).  Minnesota courts (and other jurisdictions) have long relied on the disproportionate forfeiture doctrine as a way to prevent inequitable penalties in contracts, although the doctrine is not uniformly interpreted.  In Capistrant, while the court confronted the specific question of “whether a former employee’s delay in returning his employer’s property excuses the employer from paying a commission otherwise due to the employee,” its interpretation of the disproportionate forfeiture doctrine may have wider application.

Continue Reading Minnesota Supreme Court Clarifies The Disproportionate Forfeiture Doctrine