Minnesota
How Adickes v. S.H. Kress & Co. applies in Minnesota: state-specific rules, key cases, and bar exam notes for Civil Procedure.
In Minnesota, the principles established in Adickes v. S.H. Kress & Co. regarding summary judgment apply similarly to its state laws. As in the federal system, Minnesota emphasizes the necessity for parties to establish a genuine dispute of material fact in opposing summary judgment motions.
Under Minnesota Rule of Civil Procedure 56.03, a party may be granted summary judgment only if there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.
The Minnesota Supreme Court held that the defendant’s motion for summary judgment was improperly granted because there existed material facts that were in dispute.
The appellate court reversed a summary judgment, determining that the plaintiff had provided sufficient evidence to support their claims against the defendant.
The Minnesota Court of Appeals found that summary judgment was inappropriate due to the existence of conflicting evidence regarding the defendant's negligence.
Minnesota's approach aligns with the federal summary judgment standard as articulated in Rule 56 of the Federal Rules of Civil Procedure. However, Minnesota courts tend to give slightly more leeway to non-moving parties in sufficiency of evidence to establish factual disputes.
The principles from Adickes v. S.H. Kress & Co. may come up on the Minnesota bar exam, particularly in questions assessing summary judgment and burden-shifting in civil cases.