pari materia doctrine (Minnesota) · Go Syfert
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pari materia doctrine in Minnesota

11 Minnesota opinions name it 2 courts 1994–2017 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 (11)

CaseFollowedCited
State v. Lucasgreen
minn · 1999 · cited in 4 Minnesota opinions naming this issue, 2006–2016
2 sentences

2016But the in pari materia doctrine is a tool for interpreting ambiguous statutory language, State v. Lucas, 589 N.W.2d 91, 94 (Minn. 1999), and we conclude that section 56.01(a) is unambiguous.

2006Apple Valley Red-E-Mix, Inc. v. State by Dept. of Public Safety, 352 N.W.2d 402, 404 (Minn.1984) (explaining the doctrine of in pari materia); see also State v. Lucas, 589 N.W.2d 91, 94 (Minn. 1999) (“The doctrine of in pari materia is a tool of statutory interpretation that allows two statutes with common purposes and subject matter to be construed together to determine the meaning of ambiguous statutory language.”).

44
State v. Nelsongreen
minn · 2014 · cited in 2 Minnesota opinions naming this issue, 2016–2017
2 sentences

2017See, e.g., Nelson, 842 N.W.2d at 444 ; State v. Rick, 835 N.W.2d 478, 485-87 (Minn. 2013) (holding that the communicable-disease statute was ambiguous, and ruling for the defendant based on the rule of lenity and relevant legislative history); State v. Leathers, 799 N.W.2d 606, 611 (Minn. 2011) (ruling for the defendant in light of an ambiguous criminal statute based on the doctrine of in pari materia and the rule of lenity).

2016In pari materia is a canon of statutory interpretation that “allows two statutes with common purposes and subject matter to be construed together to determine the meaning of ambiguous statutory language.” State v. Nelson, 842 N.W.2d 433, 441-42 (Minn. 2014) (quotations omitted).

22
State v. Leathersgreen
minn · 2011 · cited in 2 Minnesota opinions naming this issue, 2017–2017
2 sentences

2017After concluding that the statutory language was ambiguous, we applied the doctrine of in pari materia and the rule of lenity, and we concluded that “the definition of the phrase ‘full term of imprisonment’ in Minn. Stat. § 609.221 , subd. 2(b), means two-thirds of a defendant’s executed prison sentence.” Leathers, 799 N.W.2d at 611 .

2017See, e.g., Nelson, 842 N.W.2d at 444 ; State v. Rick, 835 N.W.2d 478, 485-87 (Minn. 2013) (holding that the communicable-disease statute was ambiguous, and ruling for the defendant based on the rule of lenity and relevant legislative history); State v. Leathers, 799 N.W.2d 606, 611 (Minn. 2011) (ruling for the defendant in light of an ambiguous criminal statute based on the doctrine of in pari materia and the rule of lenity).

12
State v. McKowngreen
minn · 1991 · cited in 2 Minnesota opinions naming this issue, 1994–1999
2 sentences

1999In pari materia is a tool of statutory construction applicable “in certain instances to determine the meaning of ambiguous statutory language.” McKown, 475 N.W.2d at 67 .

1994See, e.g., McKown, 475 N.W.2d at 65 (rules of statutory construction, including doctrine of in pari materia, only may be used to interpret ambiguous statutes). *494 DECISION Minn.Stat. § 169.791, subd. 2 unambiguously establishes that failure to provide proof of insurance is a strict liability offense when the driver is the owner of the car.

12
State v. Rickgreen
minn · 2013 · cited in 1 Minnesota opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., Nelson, 842 N.W.2d at 444 ; State v. Rick, 835 N.W.2d 478, 485-87 (Minn. 2013) (holding that the communicable-disease statute was ambiguous, and ruling for the defendant based on the rule of lenity and relevant legislative history); State v. Leathers, 799 N.W.2d 606, 611 (Minn. 2011) (ruling for the defendant in light of an ambiguous criminal statute based on the doctrine of in pari materia and the rule of lenity).

11
State v. Grigsbygreen
minn · 2012 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016See State v. Grigsby, 818 N.W.2d 511, 517 (Minn. 2012) (stating that rule of lenity does not apply if challenged statute is unambiguous); State v. Lucas, 589 N.W.2d 91, 94 (Minn. 1999) (stating that doctrine of in pari materia is not used absent statutory ambiguity).

11
McNeice v. City of Minneapolisgreen
minn · 1957 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015See McNeice v. City of Minneapolis, 250 Minn. 142, 146-47 , 84 N.W.2d 232, 236 (1957) (applying the definition of gambling devices in section 325.53 to gambling devices in sections 614.06 and 614.07).

2015See McNeice v. City of Minneapolis, 250 Minn. 142, 146-47 , 84 N.W.2d 232, 236 (1957) (applying the definition of gambling devices in section 325.53 to gambling devices in sections 614.06 and 614.07).

11
In Re the Welfare of the Children of N.F.green
minn · 2008 · cited in 1 Minnesota opinions naming this issue, 2010–2010
1 sentence

2010See In re Welfare of Children of N.F., 749 N.W.2d 802, 807 (Minn.2008) (noting doctrine of in pari materia, by which statutes with common subject matter and purposes are construed together).

11
Apple Valley Red-E-Mix, Inc. v. State Ex Rel. Department of Public Safetygreen
minn · 1984 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006Apple Valley Red-E-Mix, Inc. v. State by Dept. of Public Safety, 352 N.W.2d 402, 404 (Minn.1984) (explaining the doctrine of in pari materia); see also State v. Lucas, 589 N.W.2d 91, 94 (Minn. 1999) (“The doctrine of in pari materia is a tool of statutory interpretation that allows two statutes with common purposes and subject matter to be construed together to determine the meaning of ambiguous statutory language.”).

2006Apple Valley Red-E-Mix, Inc. v. State by Dept. of Public Safety, 352 N.W.2d 402, 404 (Minn.1984) (explaining the doctrine of in pari materia ); see also State v. Lucas, 589 N.W.2d 91, 94 (Minn. 1999) ("The doctrine of in pari materia is a tool of statutory interpretation that allows two statutes with common purposes and subject matter to be construed together to determine the meaning of ambiguous statutory language.").

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

1999State v. Murphy, 545 N.W.2d 909, 914 (Minn.1996). i On appeal to this court, Lucas does not claim that the language of Minn.Stat. § 169.685, subd. 5(b) is ambiguous, and he correctly concedes that the doctrine of in pari materia does not apply to this case.

11
Hahn v. City of Ortonvillegreen
minn · 1953 · cited in 1 Minnesota opinions naming this issue, 1995–1995
2 sentences

1995Cf. Hahn v. City of Ortonville, 238 Minn. 428, 435 , 57 N.W.2d 254, 261 (1953) (under doctrine of in pari materia, different legislative acts involving single subject must be construed to avoid irreconcilable differences and conflicts).

1995Cf. Hahn v. City of Ortonville, 238 Minn. 428, 435 , 57 N.W.2d 254, 261 (1953) (under doctrine of in pari materia, different legislative acts involving single subject must be construed to avoid irreconcilable differences and conflicts).

11

Distinguished, questioned or overruled (0)

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

Statutes the citing opinions construe

MN § Minn. Stat. § 645.16 (5)

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

TX 109 (1952–2026) IL 98 (1979–2026) MI 77 (1988–2026) FL 43 (2005–2025) OH 40 (1922–2026) MN 11 (1994–2017) MS 10 (1989–2023) AZ 10 (1988–2025) WV 8 (1986–2024) MO 8 (2016–2022) PA 8 (2010–2023) KY 6 (1920–2019) NJ 5 (1975–2022) HI 4 (2006–2025) MD 4 (1986–2025) IA 4 (1995–2007) CA 3 (1963–1988) WI 3 (1987–2020) CO 3 (2009–2013) IN 3 (1956–2018) VA 3 (2023–2025) NV 2 (2022–2022) GA 2 (2015–2016) ID 2 (2014–2023) NC 2 (1925–2007) AL 2 (1987–2026) TN 2 (2015–2018) CT 2 (1983–1999)

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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