third-party claim (Minnesota) · Go Syfert
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third-party claim in Minnesota

19 Minnesota opinions name it 2 courts 1933–2026 2 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 (9)

CaseFollowedCited
Carpenter v. United Statesgreen
scotus · 2018 · cited in 2 Minnesota opinions naming this issue, 2026–2026
2 sentences

2026In Carpenter, the Court declined to extend the third-party doctrine to CSLI even though cell phone users share their locations with their wireless carriers. 585 U.S. at 308–10.

2026The Carpenter Court noted that the government’s request to exclude “the exhaustive chronicle of location information casually collected by 20 wireless carriers” from Fourth Amendment protection represented “a significant extension of [the third-party doctrine] to a distinct category of information.” Id. at 314.

22
Larson v. Stategreen
minn · 2010 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016See Minn.Stat. § 645.08(1) (“[Wjords and phrases are construed according to rules of grammar ,. ”)• In particular, the last antecedent canon “instructs that a limiting phrase ... ordinarily modifies only the noun or phrase that it immediately follows.... ” Larson v. State, 790 N.W.2d 700, 705 (Minn.2010).

11
American Family Insurance Group v. Schroedlgreen
minn · 2000 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015This interpretation is counter to Minn.Stat. § 645.16 (2014), providing that “[ejvery law shall be construed, if possible, to give effect to all its provisions.” See also Sehroedl, 616 N.W.2d at 277 (stating that “no word, phrase, or sentence should be deemed superfluous, void, or insignificant” (quotation omitted)).

11
Bobich v. Ojagreen
minn · 1960 · cited in 1 Minnesota opinions naming this issue, 2012–2012
2 sentences

2012See Bobich v. Oja, 258 Minn. 287, 294 , 104 N.W.2d 19, 24 (1960) (stating that the extent of an insurer’s liability is governed by the insurance policy).

2012See Bobich v. Oja, 258 Minn. 287, 294 , 104 N.W.2d 19, 24 (1960) (stating that the extent of an insurer’s liability is governed by the insurance policy).

11
City of Willmar v. Short-Elliott-Hendrickson, Inc.green
minn · 1994 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006Contribution and indemnity claims are “venerable equity actions and part of our state’s common law.” City of Willmar v. Short-Elliott-Hendrickson, Inc., 512 N.W.2d 872, 874 (Minn.1994); see also Lambertson v. Cincinnati Corp., 312 Minn. 114, 122 , 257 N.W.2d 679, 685 (1977) (stating “Contribution and indemnity are variant common-law remedies used to secure restitution and fair apportionment of loss among those whose activities combine to produce injury.”); Grothe v. Shaffer, 305 Minn. 17, 25 , 232 N.W.2d 227, 233 (1975) (stating, “The third-party claim is thus contingent on the outcome of the

2006Contribution and indemnity claims are "venerable equity actions and part of our state's common law." City of Willmar v. Short-Elliott-Hendrickson, Inc., 512 N.W.2d 872, 874 (Minn.1994); see also Lambertson v. Cincinnati Corp., 312 Minn. 114, 122 , 257 N.W.2d 679, 685 (1977) (stating "Contribution and indemnity are variant common-law remedies used to secure restitution and fair apportionment of loss among those whose activities combine to produce injury."); Grothe v. Shaffer, 305 Minn. 17, 25 , 232 N.W.2d 227, 233 (1975) (stating, "The third-party claim is thus contingent on the outcome of the

11
Lambertson v. Cincinnati Corp.green
minn · 1977 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006Contribution and indemnity claims are "venerable equity actions and part of our state's common law." City of Willmar v. Short-Elliott-Hendrickson, Inc., 512 N.W.2d 872, 874 (Minn.1994); see also Lambertson v. Cincinnati Corp., 312 Minn. 114, 122 , 257 N.W.2d 679, 685 (1977) (stating "Contribution and indemnity are variant common-law remedies used to secure restitution and fair apportionment of loss among those whose activities combine to produce injury."); Grothe v. Shaffer, 305 Minn. 17, 25 , 232 N.W.2d 227, 233 (1975) (stating, "The third-party claim is thus contingent on the outcome of the

2006Contribution and indemnity claims are "venerable equity actions and part of our state's common law." City of Willmar v. Short-Elliott-Hendrickson, Inc., 512 N.W.2d 872, 874 (Minn.1994); see also Lambertson v. Cincinnati Corp., 312 Minn. 114, 122 , 257 N.W.2d 679, 685 (1977) (stating "Contribution and indemnity are variant common-law remedies used to secure restitution and fair apportionment of loss among those whose activities combine to produce injury."); Grothe v. Shaffer, 305 Minn. 17, 25 , 232 N.W.2d 227, 233 (1975) (stating, "The third-party claim is thus contingent on the outcome of the

11
Grothe Ex Rel. Grothe v. Shaffergreen
minn · 1975 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006Contribution and indemnity claims are "venerable equity actions and part of our state's common law." City of Willmar v. Short-Elliott-Hendrickson, Inc., 512 N.W.2d 872, 874 (Minn.1994); see also Lambertson v. Cincinnati Corp., 312 Minn. 114, 122 , 257 N.W.2d 679, 685 (1977) (stating "Contribution and indemnity are variant common-law remedies used to secure restitution and fair apportionment of loss among those whose activities combine to produce injury."); Grothe v. Shaffer, 305 Minn. 17, 25 , 232 N.W.2d 227, 233 (1975) (stating, "The third-party claim is thus contingent on the outcome of the

2006Contribution and indemnity claims are "venerable equity actions and part of our state's common law." City of Willmar v. Short-Elliott-Hendrickson, Inc., 512 N.W.2d 872, 874 (Minn.1994); see also Lambertson v. Cincinnati Corp., 312 Minn. 114, 122 , 257 N.W.2d 679, 685 (1977) (stating "Contribution and indemnity are variant common-law remedies used to secure restitution and fair apportionment of loss among those whose activities combine to produce injury."); Grothe v. Shaffer, 305 Minn. 17, 25 , 232 N.W.2d 227, 233 (1975) (stating, "The third-party claim is thus contingent on the outcome of the

11
Sundberg v. Abbottgreen
minnctapp · 1988 · cited in 1 Minnesota opinions naming this issue, 1994–1994
1 sentence

1994Sundberg v. Abbott, 423 N.W.2d 686, 690 (Minn.App.1988) (emphasis in original), pet. for rev. denied (Minn. June 29, 1988). *123 Porta-Mix’s answer in the prior declaratory judgment action brought by Western alleged, in part, that the policy issued by Western provided coverage for Porta-Mix for the third party claim brought against it by Vi-gen.

11
Koenigs v. Travisgreen
minn · 1956 · cited in 1 Minnesota opinions naming this issue, 1991–1991
2 sentences

1991Koenigs v. Travis, 246 Minn. 466, 469 , 75 N.W.2d 478, 481 (1956).

1991Koenigs v. Travis, 246 Minn. 466, 469 , 75 N.W.2d 478, 481 (1956).

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 (16)

CaseCitedYears
Smith v. Maryland red
scotus · 1979
2 sentences

2026CSLI, the Court reasoned, is in a different category of information entirely, as it provides a “detailed chronicle of a person’s physical presence compiled every day, every moment, over several years” and so “implicates privacy concerns far beyond those considered in Smith and Miller.” Id. at 315 . 9 The Supreme Court described a pen register as “a mechanical device that records the numbers dialed on a telephone by monitoring the electrical impulses caused when the dial on the telephone is released.” Smith, 442 U.S. at 736 n.1 (citation omitted). 21 The Court also rejected the government’s arg

2026Id.

12026–2026
United States v. Naftalin green
scotus · 1979
2 sentences

2016The immediately preceding text and the third-party clause are separated only by a comma, not by a semicolon or a line break. “[W]hile matters like punctuation are not decisive of the construction of a statute, where they reaffirm conclusions drawn from the words themselves they provide useful confirmation.” United States v. Naftalin, 441 U.S. 768 , 774 n. 5, 99 S.Ct. 2077 , 60 L.Ed.2d 624 (1979) (citations omitted) (internal quotations omitted).

2016The immediately preceding text and the third-party clause are separated only by a comma, not by a semicolon or a line break. “[W]hile matters like punctuation are not decisive of the construction of a statute, where they reaffirm conclusions drawn from the words themselves they provide useful confirmation.” United States v. Naftalin, 441 U.S. 768 , 774 n. 5, 99 S.Ct. 2077 , 60 L.Ed.2d 624 (1979) (citations omitted) (internal quotations omitted).

12016–2016
Pine Island Farmers Coop v. Erstad & Riemer, P.A. green
minn · 2002
1 sentence

2012In Pine Island, the plaintiff insurer and the insured brought a legal malpractice claim against Erstad & Riemer, the law firm appointed to represent the insured in the liability action, for failure to assert a third-party claim. 649 N.W.2d at 445-46 .

12012–2012
Calder v. City of Crystal green
minn · 1982
1 sentence

2005Moreover, Calder makes clear that a statute of limitations or repose that provides no time for a third-party claim for contribution or indemnity would violate the due-process and remedies clauses. 318 N.W.2d at 844 .

12005–2005
Insurance Commissioner v. Property & Casualty Insurance green
md · 1988
1 sentence

2004Comm’r, 546 A.2d at 463 ; see also Sands v. Pa. Ins.

12004–2004
Peterson v. Eishen green
minn · 1994
1 sentence

2003Generally, a defendant submits to the court’s jurisdiction only by taking some affirmative step invoking the power of the court or implicitly recognizing its jurisdiction. 1 David F. Herr & Roger S. Haydock, Minnesota Practice § 12.17, at 346 (2002) (citing Peterson v. Eishen, 512 N.W.2d 338 (Minn.1994)).

12003–2003
Hoyt Inv. v. BLOOMINGTON COM. & TR. CTR. green
minn · 1988
1 sentence

1990Id. at 176 .

11990–1990
Henning v. Wineman green
minn · 1981
1 sentence

1986After Morrison filed a third-party claim against the other motorist and settled for policy limits of $25,000, he moved the district court for an order allocating the entire $25,000 as and for non-recoverable costs, pursuant to Minn.Stat. § 176.061 (1984) and Henning v. Wineman, 306 N.W.2d 550 (Minn.1981).

11986–1986
Hammerschmidt v. Moore green
minn · 1978
2 sentences

1981Even though no notice of claim was ever filed with Circle Pines, nor any action commenced within three years, the third-party claim was proper because of this court’s recent holding in Hammerschmidt v. Moore, 274 N.W.2d 79 (Minn.1978), discussed in Note, Contribution & Indemnity — An Examination of the Upheaval in Minnesota Tort Loss Allocation Concepts, 5 Wm.

1981Even though no notice of claim was ever filed with Circle Pines, nor any action commenced within three years, the third-party claim was proper because of this court's recent holding in Hammerschmidt v. Moore, 274 N.W.2d 79 (Minn.1978), discussed in Note, Contribution & Indemnity — An Examination of the Upheaval in Minnesota Tort Loss Allocation Concepts, 5 Wm.

11981–1981
Markey v. Skog green
njsuperctappdiv · 1974
2 sentences

1978In that situation the tortfeasor who has been sued “has the right to implead the unjoined joint tortfeasor in plaintiff’s action for the purpose of proving their common liability even after the statute of limitations on plaintiff’s claim has run.” Markey v. Skog, 129 N.J.

1978In that situation the tortfeasor who has been sued "has the right to implead the unjoined joint tortfeasor in plaintiff's action for the purpose of proving their common liability even after the statute of limitations on plaintiff's claim has run." Markey v. Skog, 129 N.J.

11978–1978
Nyquist v. Batcher green
minn · 1952
2 sentences

1977Inc. 293 Minn. 201 , 197 N. W. 2d 656 (1972), the rule of Nyquist v. Batcher, 235 Minn. 491 , 51 N. W. 2d 566 (1952), and held that the employer’s contributory negligence was not available to the third party as a defense, since the rights of the employee in the third-party action were primary.

1977Inc. 293 Minn. 201 , 197 N. W. 2d 656 (1972), the rule of Nyquist v. Batcher, 235 Minn. 491 , 51 N. W. 2d 566 (1952), and held that the employer’s contributory negligence was not available to the third party as a defense, since the rights of the employee in the third-party action were primary.

11977–1977
Froysland v. Leef Bros., Inc. green
minn · 1972
2 sentences

1977Inc. 293 Minn. 201 , 197 N. W. 2d 656 (1972), the rule of Nyquist v. Batcher, 235 Minn. 491 , 51 N. W. 2d 566 (1952), and held that the employer’s contributory negligence was not available to the third party as a defense, since the rights of the employee in the third-party action were primary.

1977Inc. 293 Minn. 201 , 197 N. W. 2d 656 (1972), the rule of Nyquist v. Batcher, 235 Minn. 491 , 51 N. W. 2d 566 (1952), and held that the employer’s contributory negligence was not available to the third party as a defense, since the rights of the employee in the third-party action were primary.

11977–1977
Mjos Ex Rel. Mjos v. Village of Howard Lake green
minn · 1970
2 sentences

1973Third-party defendant Sorenson maintains that the decision in Mjos v. Village of Howard Lake, 287 Minn. 427 , 178 N. W. 2d 862 (1970) is controlling.

1973Third-party defendant Sorenson maintains that the decision in Mjos v. Village of Howard Lake, 287 Minn. 427 , 178 N. W. 2d 862 (1970) is controlling.

11973–1973
Pangalos v. Halpern green
minn · 1956
2 sentences

1967Third-party defendant Leary cites Pangalos v. Halpern, 247 Minn. 80 , 76 N. W. (2d) 702 , as an aid in ascertaining the extent to which defendant city is bound by the consent judgment entered pursuant to the stipulation.

1967Third-party defendant Leary cites Pangalos v. Halpern, 247 Minn. 80 , 76 N. W. (2d) 702 , as an aid in ascertaining the extent to which defendant city is bound by the consent judgment entered pursuant to the stipulation.

11967–1967
Thornton Bros. v. Northern States Power Co. neutral
minn · 1922
2 sentences

1933Co. v. Northern States Power Co. 151 Minn. 435 , 186 N. W. 863 , 187 N. W. 610 , it Avas stated that whether the contributory negligence of a workman who has received compensation from his employer can be asserted by a third party as a defense Aidien sued by the employer to recover the amount of compensation paid is an open question in this state.

1933Co. v. Northern States Power Co. 151 Minn. 435 , 186 N. W. 863 , 187 N. W. 610 , it Avas stated that whether the contributory negligence of a workman who has received compensation from his employer can be asserted by a third party as a defense Aidien sued by the employer to recover the amount of compensation paid is an open question in this state.

11933–1933
Welsh v. Estate of Welsh neutral
minn · 1922
1 sentence

1933Co. v. Northern States Power Co. 151 Minn. 435 , 186 N. W. 863 , 187 N. W. 610 , it Avas stated that whether the contributory negligence of a workman who has received compensation from his employer can be asserted by a third party as a defense Aidien sued by the employer to recover the amount of compensation paid is an open question in this state.

11933–1933

Statutes the citing opinions construe

MN § Minn. Stat. § 645.16 (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

NY 269 (1900–2026) CA 232 (1921–2026) TX 175 (1972–2026) IL 137 (1907–2026) MD 68 (1962–2023) FL 59 (1965–2022) LA 53 (1959–2025) NJ 52 (1959–2025) PA 48 (1975–2025) MO 44 (1961–2022) OR 44 (1970–2024) MI 42 (1969–2025) MA 42 (1972–2026) AZ 36 (1957–2025) WA 36 (1928–2026) VA 34 (1946–2025) NM 31 (1968–2020) WI 31 (1942–2025) OH 30 (1983–2026) GA 29 (1917–2025) AL 28 (1915–2014) IA 27 (1961–2024) IN 26 (1979–2020) CO 24 (1973–2025) TN 21 (1975–2026) WV 21 (1986–2017) NE 20 (1919–2024) NC 20 (1977–2024) MT 20 (1943–2019) CT 20 (1990–2026) MN 19 (1933–2026) SC 18 (1984–2022) WY 16 (1985–2026) UT 16 (1976–2026) DE 15 (1968–2025) MS 14 (1963–2025) ND 14 (1973–2022) KY 13 (1978–2023) AR 13 (1919–2014) OK 12 (1955–2024) HI 12 (1972–2026) DC 12 (1983–2021) ME 11 (1982–2023) KS 9 (1980–2025) RI 8 (1997–2023) AK 7 (1979–2024) NV 7 (1950–2015) VT 5 (2000–2026) ID 5 (1936–2015) NH 5 (1974–2010) SD 3 (1958–2015) PR 2 (1964–1986) VI 2 (2017–2026)

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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