equitable subrogation doctrine (Minnesota) · Go Syfert
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equitable subrogation doctrine in Minnesota

9 Minnesota opinions name it 2 courts 1977–2025 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
Sucker v. Cranmergreen
minn · 1914 · cited in 2 Minnesota opinions naming this issue, 1977–2025
2 sentences

2025Co. v. Rohde, 820 N.W.2d 1 , 10–14 (Minn. 2012) (discussing an insurer’s right to pursue an equitable subrogation claim against an insured’s negligent tenant); First Nat’l Bank of Menahga v. Schunk, 276 N.W. 290 , 292– 93 (Minn. 1937) (discussing the right of a lender who paid off a senior mortgage on a property to be equitably subrogated to the rights of the senior mortgagee); Sucker v. Cranmer, 149 N.W. 16, 18 (Minn. 1914) (discussing the rights of a purchaser at a foreclosure sale who paid taxes on a property during the redemption period to be equitably 11 subrogated to the State’s right to

1977Sucker v. Cranmer, 127 Minn. 124 , 149 N.W. 16 (1914); Elliott v. Tainter, 88 Minn. 377 , 93 N.W. 124 (1903); Emmert v. Thompson, 49 Minn. 386 , 52 N.W. 31 (1892).

12
First National Bank v. Schunkgreen
minn · 1937 · cited in 2 Minnesota opinions naming this issue, 2003–2025
2 sentences

2025Co. v. Rohde, 820 N.W.2d 1 , 10–14 (Minn. 2012) (discussing an insurer’s right to pursue an equitable subrogation claim against an insured’s negligent tenant); First Nat’l Bank of Menahga v. Schunk, 276 N.W. 290 , 292– 93 (Minn. 1937) (discussing the right of a lender who paid off a senior mortgage on a property to be equitably subrogated to the rights of the senior mortgagee); Sucker v. Cranmer, 149 N.W. 16, 18 (Minn. 1914) (discussing the rights of a purchaser at a foreclosure sale who paid taxes on a property during the redemption period to be equitably 11 subrogated to the State’s right to

2003First Nat’l Bank of Menahga v. Schunk, 201 Minn. 359, 363 , 276 N.W. 290, 292-93 (1937).

12
Emmert v. Thompsongreen
minn · 1892 · cited in 2 Minnesota opinions naming this issue, 1977–2005
2 sentences

2005See, e.g., Emmert v. Thompson, 49 Minn. 386 , 52 N.W. 31 (1892).

2005See, e.g., Emmert v. Thompson, 49 Minn. 386 , 52 N.W. 31 (1892).

12
Ripley v. Piehlgreen
minnctapp · 2005 · cited in 1 Minnesota opinions naming this issue, 2024–2024
1 sentence

2024Under the doctrine of equitable subrogation, a party “who has discharged the debt of another may succeed in substitution to the rights and position of the satisfied creditor.” Ripley v. Piehl, 700 N.W.2d 540, 545 (Minn. App. 2005).

11
Admiral Merchants Motor Freight, Inc. v. O'Connor & Hannangreen
minn · 1992 · cited in 1 Minnesota opinions naming this issue, 2002–2002
1 sentence

2002Motor Freight, Inc. v. O'Connor & Hannan, 494 N.W.2d 261, 266 (Minn.1992).

11
Marker v. Greenberggreen
minn · 1981 · cited in 1 Minnesota opinions naming this issue, 2002–2002
1 sentence

2002Co. v. Vaccari, 310 Minn. 97, 99 , 245 N.W.2d 844 , 846 (1976). [2] The district court's dismissal with prejudice of all of Farmland's claims was inconsistent with its conclusion that Farmland could maintain a legal malpractice claim against Erstad & Riemer under the doctrine of equitable subrogation. [3] Given that the district court's order dismissed all of Farmland's claims, it is unclear what was accomplished by the court of appeals' reversal of the district court on this issue. [4] We have recognized an exception to this rule, extending an attorney's duty to a nonclient in a "narrow range

11
Rouse v. Dunkley & Bennett, P.A.green
minn · 1994 · cited in 1 Minnesota opinions naming this issue, 2002–2002
2 sentences

2002See Rouse v. Dunkley & Bennett, P.A., 520 N.W.2d 406, 408 (Minn.1994); Blue Water Corp., 336 N.W.2d at 282 .

2002See Rouse v. Dunkley & Bennett, P.A., 520 N.W.2d 406, 408 (Minn.1994); Blue Water Corp., 336 N.W.2d at 282 .

11
Milbrandt v. American Legion Post of Moragreen
minn · 1985 · cited in 1 Minnesota opinions naming this issue, 1995–1995
1 sentence

1995See Milbrandt v. American Legion Post, 372 N.W.2d 702, 705 (Minn.1985) (refusing to recognize an equitable subrogation claim because it would upset the balance of the No-Fault Act).

11
Rawson v. City of Omahagreen
neb · 1982 · cited in 1 Minnesota opinions naming this issue, 1987–1987
2 sentences

1987Rawson v. City of Omaha, 212 Neb. 159 , 322 N.W.2d 381, 385 (1982).

1987Rawson v. City of Omaha, 212 Neb. 159 , 322 N.W.2d 381, 385 (1982).

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 (9)

CaseCitedYears
Ram Mutual Insurance Co. v. Rohde green
minn · 2012
1 sentence

2025Co. v. Rohde, 820 N.W.2d 1 , 10–14 (Minn. 2012) (discussing an insurer’s right to pursue an equitable subrogation claim against an insured’s negligent tenant); First Nat’l Bank of Menahga v. Schunk, 276 N.W. 290 , 292– 93 (Minn. 1937) (discussing the right of a lender who paid off a senior mortgage on a property to be equitably subrogated to the rights of the senior mortgagee); Sucker v. Cranmer, 149 N.W. 16, 18 (Minn. 1914) (discussing the rights of a purchaser at a foreclosure sale who paid taxes on a property during the redemption period to be equitably 11 subrogated to the State’s right to

12025–2025
Carl H. Peterson Co. v. Zero Estates green
minn · 1977
2 sentences

2025In reaching this conclusion, the court of appeals relied on our decision in Peterson, which involved a mechanic’s lien foreclosure action in which a bank claimed priority through its mortgage under the doctrine of equitable subrogation. 261 N.W.2d at 347–48.

2025We held in Peterson that equitable subrogation was available “where one party has provided funds used to discharge another’s 10 obligations if (a) the party seeking subrogation has acted under a justifiable or excusable mistake of fact and (b) injury to innocent parties will otherwise result.” Id. at 348 .

12025–2025
Travelers Indemnity Co. v. Vaccari green
minn · 1976
1 sentence

2002Co. v. Vaccari, 310 Minn. 97, 99 , 245 N.W.2d 844 , 846 (1976). [2] The district court's dismissal with prejudice of all of Farmland's claims was inconsistent with its conclusion that Farmland could maintain a legal malpractice claim against Erstad & Riemer under the doctrine of equitable subrogation. [3] Given that the district court's order dismissed all of Farmland's claims, it is unclear what was accomplished by the court of appeals' reversal of the district court on this issue. [4] We have recognized an exception to this rule, extending an attorney's duty to a nonclient in a "narrow range

12002–2002
Travelers Indemnity Co. v. Vaccari green
minn · 1976
1 sentence

2002Co. v. Vaccari, 310 Minn. 97, 99 , 245 N.W.2d 844 , 846 (1976). [2] The district court's dismissal with prejudice of all of Farmland's claims was inconsistent with its conclusion that Farmland could maintain a legal malpractice claim against Erstad & Riemer under the doctrine of equitable subrogation. [3] Given that the district court's order dismissed all of Farmland's claims, it is unclear what was accomplished by the court of appeals' reversal of the district court on this issue. [4] We have recognized an exception to this rule, extending an attorney's duty to a nonclient in a "narrow range

12002–2002
Atlanta International Insurance v. Bell green
mich · 1991
2 sentences

2002After acknowledging that “there is no Minnesota law on this issue,” the district court relied exclusively on Atlanta International Insurance Co. v. Bell, 438 Mich. 512 , 475 N.W.2d 294 (1991), in which the Michigan Supreme Court applied the doctrine of equitable subrogation to allow a nonclient insurer to bring a legal malpractice claim against attorneys hired by the insurer to defend an action against the insured.

2002After acknowledging that “there is no Minnesota law on this issue,” the district court relied exclusively on Atlanta International Insurance Co. v. Bell, 438 Mich. 512 , 475 N.W.2d 294 (1991), in which the Michigan Supreme Court applied the doctrine of equitable subrogation to allow a nonclient insurer to bring a legal malpractice claim against attorneys hired by the insurer to defend an action against the insured.

12002–2002
Pine Island Farmers Coop v. Erstad & Riemer, P.A. green
minnctapp · 2001
1 sentence

2002Id. at 611 . *448 Farmland and Pine Island petitioned this court for review of the court of appeals' decision, and we granted the petition to consider two issues: first, whether Erstad & Riemer and Farmland had an attorney-client relationship; and second, if Erstad & Riemer and Farmland did not have an attorney-client relationship, whether Farmland can maintain a legal malpractice action against Erstad & Riemer under the doctrine of equitable subrogation.

12002–2002
Blue Water Corp., Inc. v. O'TOOLE green
minn · 1983
2 sentences

2002See Rouse v. Dunkley & Bennett, P.A., 520 N.W.2d 406, 408 (Minn.1994); Blue Water Corp., 336 N.W.2d at 282 .

2002See Rouse v. Dunkley & Bennett, P.A., 520 N.W.2d 406, 408 (Minn.1994); Blue Water Corp., 336 N.W.2d at 282 .

12002–2002
Suchy v. Illinois Farmers Insurance Co. green
minnctapp · 1998
1 sentence

1999Id.

11999–1999
Elliott v. Tainter green
minn · 1903
2 sentences

1977Sucker v. Cranmer, 127 Minn. 124 , 149 N.W. 16 (1914); Elliott v. Tainter, 88 Minn. 377 , 93 N.W. 124 (1903); Emmert v. Thompson, 49 Minn. 386 , 52 N.W. 31 (1892).

1977Sucker v. Cranmer, 127 Minn. 124 , 149 N.W. 16 (1914); Elliott v. Tainter, 88 Minn. 377 , 93 N.W. 124 (1903); Emmert v. Thompson, 49 Minn. 386 , 52 N.W. 31 (1892).

11977–1977

Where else courts name it

NY 55 (1880–2025) TX 45 (1978–2024) CA 43 (1935–2024) FL 27 (1974–2021) OH 20 (1990–2021) MI 19 (1993–2025) AZ 16 (1990–2020) IN 15 (2001–2024) GA 13 (1985–2025) AL 13 (1929–2016) WA 12 (1999–2025) NJ 12 (2000–2021) PA 11 (1920–2021) SC 11 (1993–2023) IL 11 (2001–2021) CT 9 (1986–2018) MN 9 (1977–2025) CO 8 (2005–2018) MO 7 (1984–2021) MA 6 (1999–2018) MD 6 (1890–2022) OK 6 (2000–2017) TN 5 (2008–2024) WI 5 (1997–2018) NV 5 (2012–2026) NC 5 (1994–2024) KY 4 (1960–2020) KS 4 (1919–2008) DC 3 (2011–2014) UT 3 (1993–2001) NE 3 (1943–1988) VA 3 (1997–2015) HI 2 (2001–2015) OR 2 (2004–2012)

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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