conflict doctrine (Minnesota) · Go Syfert
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conflict doctrine in Minnesota

5 Minnesota opinions name it 2 courts 1990–2016 0 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Mangold Midwest Co. v. Village of Richfieldgreen
minn · 1966 · cited in 2 Minnesota opinions naming this issue, 2000–2001
2 sentences

2001The general principles for determining whether an ordinance conflicts with state law are these: (a) Generally, conflict occurs when “the ordinance and the statute contain express or implied terms that are irreconcilable”; (b) more specifically, an ordinance conflicts with state law if it “permits what the statute forbids”; (c) similarly, there is conflict if the ordinance “forbids what the statute expressly permits”; and (d) “no conflict exists where the ordinance, though different, is merely additional and complementary to or in aid and furtherance of the statute.” Mangold Midwest Co. v. Vill

2001The general principles for determining whether an ordinance conflicts with state law are these: (a) Generally, conflict occurs when “the ordinance and the statute contain express or implied terms that are irreconcilable”; (b) more specifically, an ordinance conflicts with state law if it “permits what the statute forbids”; (c) similarly, there is conflict if the ordinance “forbids what the statute expressly permits”; and (d) “no conflict exists where the ordinance, though different, is merely additional and complementary to or in aid and furtherance of the statute.” Mangold Midwest Co. v. Vill

22
Danielson v. National Supply Co.green
minnctapp · 2003 · cited in 1 Minnesota opinions naming this issue, 2009–2009
2 sentences

2009Danielson, 670 N.W.2d at 5 (citations and quotation omitted); see also Schumacher, 676 N.W.2d at 689-90 (proceeding from a determination of whether there is a conflict to an analysis of whether the law is procedural or substantive).

2009Danielson, 670 N.W.2d at 5 (citations and quotation omitted); see also Schumacher, 676 N.W.2d at 689-90 (proceeding from a determination of whether there is a conflict to an analysis of whether the law is procedural or substantive).

11
Schumacher v. Schumachergreen
minnctapp · 2004 · cited in 1 Minnesota opinions naming this issue, 2009–2009
2 sentences

2009Danielson, 670 N.W.2d at 5 (citations and quotation omitted); see also Schumacher, 676 N.W.2d at 689-90 (proceeding from a determination of whether there is a conflict to an analysis of whether the law is procedural or substantive).

2009Danielson, 670 N.W.2d at 5 (citations and quotation omitted); see also Schumacher, 676 N.W.2d at 689-90 (proceeding from a determination of whether there is a conflict to an analysis of whether the law is procedural or substantive).

11
Liebsch v. Abbottgreen
minn · 1963 · cited in 1 Minnesota opinions naming this issue, 1990–1990
2 sentences

1990See Liebsch v. Abbott, 265 Minn. 447, 457 , 122 N.W.2d 578, 585 (1963) (if the trial court’s decision is correct, the appellate court can sustain it for a different reason).

1990See Liebsch v. Abbott, 265 Minn. 447, 457 , 122 N.W.2d 578, 585 (1963) (if the trial court’s decision is correct, the appellate court can sustain it for a different reason).

11
State v. Apple Valley Redi-Mix, Inc.green
minnctapp · 1985 · cited in 1 Minnesota opinions naming this issue, 1990–1990
1 sentence

1990See Apple Valley Redi-Mix, 379 N.W.2d at 138 (applying conflict doctrine to Minn.Stat. § 116.07, subd. 2 (1984)).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
County of Washington v. City of Oak Park Heights green
minn · 2012
2 sentences

2016Aside from creating a conflict with the rule from County of Washington, 818 N.W.2d at 542 , a long line of cases casts doubt on the concurrence’s proposed rule.4 In Dokmo v. Independent School District No. 11, for example, we concluded that the 4 The concurrence criticizes us for failing to adopt Meldahl’s “separate and distinct” test, which it says we “have already adopted.” We disagree.

2016Aside from creating a conflict with the rule from County of Washington, 818 N.W.2d at 542 , a long line of cases casts doubt on the concurrence’s proposed rule. 4 In Dokmo v. Independent School District No. 11, for example, we concluded that the “only method of appealing” a school board’s decision to deny a teacher’s reinstatement request was “by writ of certiorari.” 459 N.W.2d at 673 .

12016–2016
Dokmo v. Independent School District No. 11 green
minn · 1990
1 sentence

2016Aside from creating a conflict with the rule from County of Washington, 818 N.W.2d at 542 , a long line of cases casts doubt on the concurrence’s proposed rule. 4 In Dokmo v. Independent School District No. 11, for example, we concluded that the “only method of appealing” a school board’s decision to deny a teacher’s reinstatement request was “by writ of certiorari.” 459 N.W.2d at 673 .

12016–2016

Where else courts name it

CA 39 (1931–2023) TX 18 (1915–2025) OH 16 (1986–2023) IL 14 (1888–2023) NY 12 (1961–2023) WA 12 (1997–2023) CO 8 (2002–2026) MD 7 (1981–2026) MO 7 (1993–2023) PA 7 (1975–2024) FL 6 (1987–2024) NM 6 (1953–2023) NC 6 (2001–2022) MI 6 (1976–2013) NJ 6 (1978–2025) MN 5 (1990–2016) IA 5 (1918–2022) LA 4 (2000–2009) DC 4 (1982–2016) NV 4 (1980–2017) ID 3 (1962–1991) UT 3 (1990–2024) NE 3 (1992–2016) WI 3 (1984–2014) AK 3 (1967–2019) VA 3 (1891–2018) CT 3 (1997–2016) AL 3 (1984–1999) MA 2 (2015–2025) KS 2 (1903–1999) MS 2 (1998–2006) AZ 2 (1986–2008) ME 2 (1854–1970) VT 2 (2010–2013) SD 2 (2008–2014) IN 2 (1981–2007) KY 2 (1918–2019) AR 2 (1933–2002) GA 2 (2011–2011)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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