burden of rebutting presumption (Minnesota) · Go Syfert
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burden of rebutting presumption in Minnesota

30 Minnesota opinions name it 2 courts 1927–2016 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 (17)

CaseFollowedCited
Dozier v. Krmpotichgreen
minn · 1949 · cited in 5 Minnesota opinions naming this issue, 1949–2000
2 sentences

1975However, as this court stated in Dozier v. Krmpotich, 227 Minn. 503, 507 , 35 N. W. 2d 696, 699 (1949): “* * * Where the claimant of an easement by prescription has shown open, visible, continuous, and unmolested use for the statutory period, inconsistent with the rights of the owner of the servient estate and under circumstances from which his knowledge and acquiescence may be inferred, the use will be presumed to be under claim of right and adverse, so as to place on the owner of the servient estate the burden of rebutting the presumption by evidence that the use was permissive.” (Italics su

1975However, as this court stated in Dozier v. Krmpotich, 227 Minn. 503, 507 , 35 N. W. 2d 696, 699 (1949): “* * * Where the claimant of an easement by prescription has shown open, visible, continuous, and unmolested use for the statutory period, inconsistent with the rights of the owner of the servient estate and under circumstances from which his knowledge and acquiescence may be inferred, the use will be presumed to be under claim of right and adverse, so as to place on the owner of the servient estate the burden of rebutting the presumption by evidence that the use was permissive.” (Italics su

25
In Re the Welfare of D.L.R.D.green
minnctapp · 2003 · cited in 3 Minnesota opinions naming this issue, 2011–2013
2 sentences

2013“The party petitioning to terminate parental rights has the burden of rebutting this presumption.” Id.

2011“Under these circumstances, the parent has the burden of rebutting the presumption of palpable unfitness.” D.L.R.D., 656 N.W.2d at 250 .

23
Hartman v. Blanding's Inc.green
minn · 1970 · cited in 3 Minnesota opinions naming this issue, 1974–1987
2 sentences

1987Hartman v. Blanding’s, Inc., 288 Minn. 415, 421 , 181 N.W.2d 466, 469 (1970).

1987Hartman v. Blanding’s, Inc., 288 Minn. 415, 421 , 181 N.W.2d 466, 469 (1970).

23
In the Matter of the WELFARE OF the CHILD OF R.D.L. and J.W., Parentsgreen
minn · 2014 · cited in 2 Minnesota opinions naming this issue, 2016–2016
2 sentences

2016T.D., 731 N.W.2d at 554 . “[A] parent rebuts the presumption by introducing evidence that would justify a finding of fact that the parent is not palpably unfit, and whether the evidence satisfies the burden of production is determined on a case-by-case basis.” In re Welfare of Child of R.D.L., 853 N.W.2d 127, 137 (Minn. 2014) (quotations omitted).

2016To rebut the presumption, 4 “the parent needs to produce only enough evidence to support a finding that the parent is suitable to be entrusted with the care of the children.” R.D.L., 853 N.W.2d at 137 (quotation omitted).

22
State v. Bottgreen
minn · 1976 · cited in 2 Minnesota opinions naming this issue, 1981–1997
2 sentences

1997See State v. Bott, 310 Minn. 331, 335 , 246 N.W.2d 48, 52 (1976) (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952)); State v. Mytych, 292 Minn. 248 , 254- 55, 194 N.W.2d 276, 280-81 (1972) (placing the burden of persuasion on defendant of proving insanity did not violate the defendants’ due process rights (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952))).

1997See State v. Bott, 310 Minn. 331, 335 , 246 N.W.2d 48, 52 (1976) (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952)); State v. Mytych, 292 Minn. 248 , 254- 55, 194 N.W.2d 276, 280-81 (1972) (placing the burden of persuasion on defendant of proving insanity did not violate the defendants’ due process rights (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952))).

22
Jacobson v. $55,900 in U.S. Currencygreen
minn · 2007 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015See Jacobson v. $55,900 in U.S. Currency, 728 N.W.2d 510, 522 (Minn. 2007) (“A presumption is merely a procedural device for controlling the burden of going forward with the evidence, and it has no additional function other than the limited one of dictating 5 the decision where there is an entire lack of competent evidence to the contrary.” (quotation omitted)).

11
Federal Home Loan Mortgage Corporation v. Gary E. Mitchell, John Doegreen
minnctapp · 2015 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015See Mitchell, 2015 WL 1401595, at *3 (rejecting essentially same argument).

11
Matter of Welfare of Chosagreen
minn · 1980 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003In re Welfare of Chosa, 290 N.W.2d 766, 769 (Minn.1980); see also In re Klugman, 256 Minn. 113 , 118, 97 N.W.2d 425 , 428-29 (1959) (stating that “the presumption is that the parent is a fit and suitable person to be entrusted with the care of his child, and the burden is upon him who asserts the contrary to prove it by satisfactory evidence.”).

11
Hursh v. Klugmangreen
minn · 1959 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003In re Welfare of Chosa, 290 N.W.2d 766, 769 (Minn.1980); see also In re Klugman, 256 Minn. 113 , 118, 97 N.W.2d 425 , 428-29 (1959) (stating that “the presumption is that the parent is a fit and suitable person to be entrusted with the care of his child, and the burden is upon him who asserts the contrary to prove it by satisfactory evidence.”).

11
In Re Dependency of Klugmangreen
minn · 1959 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003In re Welfare of Chosa, 290 N.W.2d 766, 769 (Minn.1980); see also In re Klugman, 256 Minn. 113 , 118, 97 N.W.2d 425 , 428-29 (1959) (stating that “the presumption is that the parent is a fit and suitable person to be entrusted with the care of his child, and the burden is upon him who asserts the contrary to prove it by satisfactory evidence.”).

11
State v. Jonesgreen
minn · 1996 · cited in 1 Minnesota opinions naming this issue, 1999–1999
1 sentence

1999See Sullivan, 508 U.S. at 279 , 113 S.Ct. 2078 ; State v. Jones, 556 N.W.2d 903, 910 (Minn.1996) (recognizing that with respect to constitutional errors in a criminal trial, the state bears the burden of showing the error was harmless); State v. Sanders, 376 N.W.2d 196, 205 (Minn.1985) (recognizing that with respect to “presumptively prejudicial” errors, the state bears the burden of rebutting the presumption).

11
Sullivan v. Louisianagreen
scotus · 1993 · cited in 1 Minnesota opinions naming this issue, 1999–1999
2 sentences

1999See Sullivan, 508 U.S. at 279 , 113 S.Ct. 2078 ; State v. Jones, 556 N.W.2d 903, 910 (Minn.1996) (recognizing that with respect to constitutional errors in a criminal trial, the state bears the burden of showing the error was harmless); State v. Sanders, 376 N.W.2d 196, 205 (Minn.1985) (recognizing that with respect to “presumptively prejudicial” errors, the state bears the burden of rebutting the presumption).

1999See Sullivan, 508 U.S. at 279 , 113 S.Ct. 2078 ; State v. Jones, 556 N.W.2d 903, 910 (Minn.1996) (recognizing that with respect to constitutional errors in a criminal trial, the state bears the burden of showing the error was harmless); State v. Sanders, 376 N.W.2d 196, 205 (Minn.1985) (recognizing that with respect to “presumptively prejudicial” errors, the state bears the burden of rebutting the presumption).

11
State v. Sandersgreen
minn · 1985 · cited in 1 Minnesota opinions naming this issue, 1999–1999
1 sentence

1999See Sullivan, 508 U.S. at 279 , 113 S.Ct. 2078 ; State v. Jones, 556 N.W.2d 903, 910 (Minn.1996) (recognizing that with respect to constitutional errors in a criminal trial, the state bears the burden of showing the error was harmless); State v. Sanders, 376 N.W.2d 196, 205 (Minn.1985) (recognizing that with respect to “presumptively prejudicial” errors, the state bears the burden of rebutting the presumption).

11
State v. Mytychgreen
minn · 1972 · cited in 1 Minnesota opinions naming this issue, 1997–1997
2 sentences

1997See State v. Bott, 310 Minn. 331, 335 , 246 N.W.2d 48, 52 (1976) (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952)); State v. Mytych, 292 Minn. 248 , 254- 55, 194 N.W.2d 276, 280-81 (1972) (placing the burden of persuasion on defendant of proving insanity did not violate the defendants’ due process rights (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952))).

1997See State v. Bott, 310 Minn. 331, 335 , 246 N.W.2d 48, 52 (1976) (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952)); State v. Mytych, 292 Minn. 248 , 254- 55, 194 N.W.2d 276, 280-81 (1972) (placing the burden of persuasion on defendant of proving insanity did not violate the defendants’ due process rights (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952))).

11
Leland v. Oregongreen
scotus · 1952 · cited in 1 Minnesota opinions naming this issue, 1997–1997
2 sentences

1997See State v. Bott, 310 Minn. 331, 335 , 246 N.W.2d 48, 52 (1976) (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952)); State v. Mytych, 292 Minn. 248 , 254- 55, 194 N.W.2d 276, 280-81 (1972) (placing the burden of persuasion on defendant of proving insanity did not violate the defendants’ due process rights (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952))).

1997See State v. Bott, 310 Minn. 331, 335 , 246 N.W.2d 48, 52 (1976) (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952)); State v. Mytych, 292 Minn. 248 , 254- 55, 194 N.W.2d 276, 280-81 (1972) (placing the burden of persuasion on defendant of proving insanity did not violate the defendants’ due process rights (citing Leland v. Oregon, 343 U.S. 790 , 72 S.Ct. 1002 , 96 L.Ed. 1302 (1952))).

11
State v. Smithgreen
ariz · 1984 · cited in 1 Minnesota opinions naming this issue, 1996–1996
1 sentence

1996Id. at 1384.

11
State v. Jensengreen
minn · 1967 · cited in 1 Minnesota opinions naming this issue, 1976–1976
2 sentences

1976State v. Jensen, 278 Minn. 212, 217 , 153 N. W. 2d 339, 342 (1967); *115 State ex rel.

1976State v. Jensen, 278 Minn. 212, 217 , 153 N. W. 2d 339, 342 (1967); *115 State ex rel.

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 (14)

CaseCitedYears
Merrick v. Schleuder green
minn · 1930
2 sentences

1970The rule was laid down in Merrick v. Schleuder, 179 Minn. 228, 230 , 228 N. W. 755, 756 , that— <<* * * ‘where the claimant [of an easement by prescription] has shown an open, visible, continuous and unmolested use’ for the required period inconsistent with the owner’s rights and under circumstances from which may be inferred his knowledge and acquiescence, the use will be presumed to be under claim of right and adverse so as to place upon the owner [of the servient estate] the burden of rebutting this presumption by showing that the use was permissive.” The court held further ( 179 Minn. 229

1970The rule was laid down in Merrick v. Schleuder, 179 Minn. 228, 230 , 228 N. W. 755, 756 , that— <<* * * ‘where the claimant [of an easement by prescription] has shown an open, visible, continuous and unmolested use’ for the required period inconsistent with the owner’s rights and under circumstances from which may be inferred his knowledge and acquiescence, the use will be presumed to be under claim of right and adverse so as to place upon the owner [of the servient estate] the burden of rebutting this presumption by showing that the use was permissive.” The court held further ( 179 Minn. 229

41936–1970
Stapf v. Wobbrock green
minn · 1927
2 sentences

1970Schmidt v. Koecher, 196 Minn. 178 , 265 N. W. 347 ; Merrick v. Schleuder, 179 Minn. 228 , 228 N. W. 755 ; Stapf v. Wobbrock, 171 Minn. 358 , 214 N. W. 49 ; Annotation, 170 A. L.

1970Schmidt v. Koecher, 196 Minn. 178 , 265 N. W. 347 ; Merrick v. Schleuder, 179 Minn. 228 , 228 N. W. 755 ; Stapf v. Wobbrock, 171 Minn. 358 , 214 N. W. 49 ; Annotation, 170 A. L.

31949–1970
Swan v. Munch green
minn · 1896
2 sentences

1949Swan v. Munch, 65 Minn. 500 , 67 N.W. 1022 , 35 L.R.A. 743 , 60 A.S.R. 491 ; Stapf v. Wobbrock, 171 Minn. 358 , 214 N.W. 49 , and cases there cited." In Dozier v. Krmpotich, 227 Minn. 503 , 507 , 35 N.W.2d 696 , 699 , we stated: "* * * It must be apparent, therefore, that 'acquiescence' and 'permission' as used in this connection are not synonymous. 'Acquiescence,' *Page 358 regardless of what it might mean otherwise, means, when used in this connection, passive conduct on the part of the owner of the servient estate consisting of failure on his part to assert his paramount rights against the

1949Swan v. Munch, 65 Minn. 500 , 67 N.W. 1022 , 35 L.R.A. 743 , 60 A.S.R. 491 ; Stapf v. Wobbrock, 171 Minn. 358 , 214 N.W. 49 , and cases there cited." In Dozier v. Krmpotich, 227 Minn. 503 , 507 , 35 N.W.2d 696 , 699 , we stated: "* * * It must be apparent, therefore, that 'acquiescence' and 'permission' as used in this connection are not synonymous. 'Acquiescence,' *Page 358 regardless of what it might mean otherwise, means, when used in this connection, passive conduct on the part of the owner of the servient estate consisting of failure on his part to assert his paramount rights against the

31930–1949
Schmidt v. Koecher green
minn · 1936
2 sentences

1970Schmidt v. Koecher, 196 Minn. 178 , 265 N. W. 347 ; Merrick v. Schleuder, 179 Minn. 228 , 228 N. W. 755 ; Stapf v. Wobbrock, 171 Minn. 358 , 214 N. W. 49 ; Annotation, 170 A. L.

1949Schmidt v. Koecher, 196 Minn. 178 , 265 N. W. 347 ; Merrick v. Schleuder, 179 Minn. 228 , 228 N. W. 755 ; Stapf v. Wobbrock, 171 Minn. 358 , 214 N. W. 49 ; Annotation, 170 A. L.

21949–1970
In Re the Welfare of the Child of D.L.D. green
minnctapp · 2009
1 sentence

2016A parent is presumed to be palpably unfit “upon a showing that the parent’s parental rights to one or more other children were involuntarily terminated.” Id. “[T]he parent has the burden of rebutting the presumption of palpable unfitness.” In re Welfare of Child of D.L.D., 771 N.W.2d 538 , 543–44 (Minn. App. 2009) (quotation omitted).

12016–2016
In Re the Welfare of the Child of T.D. green
minnctapp · 2007
1 sentence

2016T.D., 731 N.W.2d at 554 . “[A] parent rebuts the presumption by introducing evidence that would justify a finding of fact that the parent is not palpably unfit, and whether the evidence satisfies the burden of production is determined on a case-by-case basis.” In re Welfare of Child of R.D.L., 853 N.W.2d 127, 137 (Minn. 2014) (quotations omitted).

12016–2016
Williams v. Curtis green
minnctapp · 1993
1 sentence

2013In support of his argument that the district court erred in granting summary judgment, appellant primarily relies upon our decision in Williams v. Curtis, 501 N.W.2d 653 (Minn.App.1993), review denied (Minn. Aug. 6, 1993).

12013–2013
State v. Higgin green
minn · 1959
2 sentences

1976He relies upon State v. Higgin, 257 Minn. 46 , 99 N. W. 2d 902 (1959), in which we disapproved instructing the jury that after finding the presence of one element of an offense, another element could be presumed to be present.

1976He relies upon State v. Higgin, 257 Minn. 46 , 99 N. W. 2d 902 (1959), in which we disapproved instructing the jury that after finding the presence of one element of an offense, another element could be presumed to be present.

11976–1976
Alstad v. Boyer green
minn · 1949
2 sentences

1974Hartman v. Blanding’s Inc. 288 Minn. 415 , 181 N. W. 2d 466 (1970); Alstad v. Boyer, 228 Minn. 307 , 37 N. W. 2d 372 (1949).

1974Hartman v. Blanding’s Inc. 288 Minn. 415 , 181 N. W. 2d 466 (1970); Alstad v. Boyer, 228 Minn. 307 , 37 N. W. 2d 372 (1949).

11974–1974
Thomas W. Whalem v. United States green
cadc · 1965
1 sentence

1974Standards for Criminal Justice, The Function of the Trial Judge, § 1.1(a) (Approved Draft, 1972); Whalem v. United States, 120 App.D.C. 331 , 346 F.2d 812, 818 , certiorari denied, 382 U.S. 862 , 86 S.Ct. 124 , 15 L.Ed.2d 100 (1965). [3] Minn.St. 611.025 provides: "Except as otherwise provided by law, in every criminal proceeding, a person is presumed to be responsible for his acts and the burden of rebutting such presumption is upon him." [1] It should be noted that Minn.St. 632.06 facially provides that if this court reverses a judgment in a criminal case, "it shall either direct a new trial

11974–1974
Vega v. National Labor Relations Board green
scotus · 1965
1 sentence

1974Standards for Criminal Justice, The Function of the Trial Judge, § 1.1(a) (Approved Draft, 1972); Whalem v. United States, 120 App.D.C. 331 , 346 F.2d 812, 818 , certiorari denied, 382 U.S. 862 , 86 S.Ct. 124 , 15 L.Ed.2d 100 (1965). [3] Minn.St. 611.025 provides: "Except as otherwise provided by law, in every criminal proceeding, a person is presumed to be responsible for his acts and the burden of rebutting such presumption is upon him." [1] It should be noted that Minn.St. 632.06 facially provides that if this court reverses a judgment in a criminal case, "it shall either direct a new trial

11974–1974
Naporra v. Weckwerth green
minn · 1929
2 sentences

1972Naporra v. Weckwerth, 178 Minn. 203 , 226 N. W. 569 , 65 A. L.

1972Naporra v. Weckwerth, 178 Minn. 203 , 226 N. W. 569 , 65 A. L.

11972–1972
Brown v. State green
minn · 1972
2 sentences

1972Brown v. State, 292 Minn. 174 , 193 N. W. 2d 613 (1972).

1972Brown v. State, 292 Minn. 174 , 193 N. W. 2d 613 (1972).

11972–1972
Mitchell v. Bain green
ind · 1895
11927–1927

Statutes the citing opinions construe

MN § Minn. Stat. § 260C.301 (6) MN § Minn. Stat. § 480A.08 (4) MN § Minn. Stat. § 260.012 (3) MN § Minn. Stat. § 609.185 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 341 (1851–2026) TX 190 (1938–2026) IN 91 (1913–2025) PA 62 (1925–2024) LA 48 (1973–2019) CA 47 (1865–2026) WA 47 (1918–2025) NY 46 (1922–2024) VA 45 (1924–2026) NC 37 (1893–2025) MO 35 (1908–2022) CT 31 (1934–2024) MN 30 (1927–2016) OH 29 (1978–2026) MI 27 (1978–2026) MS 26 (1985–2021) AL 20 (1891–2017) AR 20 (1982–2025) AZ 18 (1967–2026) WI 17 (1991–2025) FL 16 (1932–2019) GA 16 (1924–2019) NM 12 (1986–2026) CO 12 (1873–2020) ND 12 (1947–2020) DC 11 (1975–2024) NJ 11 (1954–2020) MD 11 (1990–2023) DE 11 (1962–2022) TN 10 (1980–2021) KY 7 (1955–2025) MT 7 (1990–1999) WV 6 (1983–2024) KS 5 (1977–2021) NV 5 (1990–2023) NE 5 (1903–2006) OR 5 (1952–2025) ID 5 (1986–2018) IA 5 (1925–2018) RI 3 (1979–2005) HI 3 (1983–2001) SC 3 (1941–2026) SD 3 (2002–2023) MA 2 (2003–2008) VT 2 (2015–2017) OK 2 (1953–1994) ME 2 (1998–2020)

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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