Minnesota
How Adickes v. S.H. Kress & Co. applies in Minnesota: state-specific rules, key cases, and bar exam notes for Other.
In Minnesota, the principles established in Adickes v. S.H. Kress & Co. concerning the requisite showing for state action and the scope of civil rights violations are integrated into the state’s commitment to protecting individual rights against discriminatory state conduct. Minnesota courts take a broad view of what constitutes state action, often extending protections to acts that might be considered private under federal standards.
In Minnesota, for a private entity's actions to be considered as state action for the purposes of civil rights violations, there must be sufficient nexus or connection demonstrated between the private party's actions and governmental authority.
The Minnesota Supreme Court held that a private security guard's actions could constitute state action if the guard was acting under the authority of a public university.
The Minnesota Court of Appeals ruled that a utility company's actions could be subject to state regulations when it acted in concert with local governmental entities.
The court concluded that state action can be found when the private actor’s conduct is effectively compelled or significantly encouraged by state policy.
Minnesota's approach to applying state action principles is more expansive than the federal standard articulated in Adickes, which necessitates a clearer alignment between private conduct and state authorization. Minnesota courts frequently assess the implications of public policy in determining state action, leading to broader protections against discrimination.
On the Minnesota bar exam, be prepared to analyze cases involving civil rights under state action principles, assessing the interplay between private actions and governmental authority.