relation-back doctrine (Minnesota) · Go Syfert
← Minnesota issues

relation-back doctrine in Minnesota

9 Minnesota opinions name it 2 courts 1985–2012 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 (10)

CaseFollowedCited
Ortiz Ex Rel. Ortiz v. Gavendagreen
minn · 1999 · cited in 2 Minnesota opinions naming this issue, 2004–2010
2 sentences

2010“The purpose of this relation back doctrine is to prevent meritorious cases from being dismissed for technical, procedural violations.” Ortiz, 590 N.W.2d at 126 .

2004See Ortiz v. Gavenda, 590 N.W.2d 119, 123 (Minn.1999).

12
Swenson v. Emerson Electric Co.green
minn · 1985 · cited in 2 Minnesota opinions naming this issue, 1998–1999
2 sentences

1999Co., 374 N.W.2d 690 (Minn.1985) (applying the relation back doctrine to permit the addition of a claim seeking damages under the federal Consumer Products Safety Act); Heyn v. Braun, 239 Minn. 496 , 59 N.W.2d 326 (1953) (applying the relation back doctrine to a mechanic’s lien action).

1999Co., 374 N.W.2d 690 (Minn.1985) (applying the relation back doctrine to permit the addition of a claim seeking damages under the federal Consumer Products Safety Act); Heyn v. Braun, 239 Minn. 496 , 59 N.W.2d 326 (1953) (applying the relation back doctrine to a mechanic's lien action).

12
Mavco, Inc. v. Egginkgreen
minn · 2007 · cited in 1 Minnesota opinions naming this issue, 2012–2012
1 sentence

2012P. 4.03 — expressly governs “[sjervice of summons.” Because the rule, by its terms, applied and was not in conflict or inconsistent with the mechanic’s lien statute, the rule controlled. 634 N.W.2d at 186; see also Mavco, 739 N.W.2d at 159 (applying the relation back doctrine in Minn. R.

11
Matter of Estate of Gerhardtgreen
minnctapp · 1985 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003In re Estate of Gerhardt, 369 N.W.2d 335, 336 (Minn.App.1985).

11
Carlson v. Hennepin Countygreen
minn · 1992 · cited in 1 Minnesota opinions naming this issue, 1999–1999
2 sentences

1999See Carlson v. Hennepin County, 479 N.W.2d 50, 57 (Minn.1992) (citing Buysse v. Baumann-Furrie & Co., 448 N.W.2d 865, 871 (Minn.1989)).

1999See, e.g., Carlson v. Hennepin County, 479 N.W.2d 50 (Minn.1992) (holding that an amendment changing the identity of the defendant to the party actually liable for the injuries could relate back to the date of original filing); Fore v. Crop Hail Management, 270 N.W.2d 13 (Minn.1978) (same); Nelson v. Glenwood Hills Hospitals, 240 Minn. 505 , 62 N.W.2d 73 (1953).

11
Grothe Ex Rel. Grothe v. Shaffergreen
minn · 1975 · cited in 1 Minnesota opinions naming this issue, 1999–1999
2 sentences

1999See Grothe v. Shaffer, 305 Minn. 17 , 232 N.W.2d 227 (1975).

1999See Grothe v. Shaffer, 305 Minn. 17 , 232 N.W.2d 227 (1975).

11
Buysse v. Baumann-Furrie & Co.green
minn · 1989 · cited in 1 Minnesota opinions naming this issue, 1999–1999
2 sentences

1999See Carlson v. Hennepin County, 479 N.W.2d 50, 57 (Minn.1992) (citing Buysse v. Baumann-Furrie & Co., 448 N.W.2d 865, 871 (Minn.1989)).

1999See Carlson v. Hennepin County, 479 N.W.2d 50, 57 (Minn.1992) (citing Buysse v. Baumann-Furrie & Co., 448 N.W.2d 865, 871 (Minn. 1989)).

11
Loegering v. County of Toddgreen
mnd · 1960 · cited in 1 Minnesota opinions naming this issue, 1998–1998
1 sentence

1998As the only party with standing to maintain a wrongful death claim, the trustee is also, at least to some extent, the “real party in interest.” Kolles v. Ross, 418 N.W.2d 733, 738 (Minn.App.1988); see also Loegering v. Todd County, 185 F.Supp. 134, 136 (D.Minn.1960), aff'd, 297 F.2d 470 (8th Cir.1961).

11
Kolles v. Rossgreen
minnctapp · 1988 · cited in 1 Minnesota opinions naming this issue, 1998–1998
1 sentence

1998As the only party with standing to maintain a wrongful death claim, the trustee is also, at least to some extent, the “real party in interest.” Kolles v. Ross, 418 N.W.2d 733, 738 (Minn.App.1988); see also Loegering v. Todd County, 185 F.Supp. 134, 136 (D.Minn.1960), aff'd, 297 F.2d 470 (8th Cir.1961).

11
County of Todd, Minn. v. Loegeringgreen
ca8 · 1961 · cited in 1 Minnesota opinions naming this issue, 1998–1998
1 sentence

1998As the only party with standing to maintain a wrongful death claim, the trustee is also, at least to some extent, the “real party in interest.” Kolles v. Ross, 418 N.W.2d 733, 738 (Minn.App.1988); see also Loegering v. Todd County, 185 F.Supp. 134, 136 (D.Minn.1960), aff'd, 297 F.2d 470 (8th Cir.1961).

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 (6)

CaseCitedYears
Heyn v. Braun green
minn · 1953
2 sentences

1999Co., 374 N.W.2d 690 (Minn.1985) (applying the relation back doctrine to permit the addition of a claim seeking damages under the federal Consumer Products Safety Act); Heyn v. Braun, 239 Minn. 496 , 59 N.W.2d 326 (1953) (applying the relation back doctrine to a mechanic’s lien action).

1999Co., 374 N.W.2d 690 (Minn.1985) (applying the relation back doctrine to permit the addition of a claim seeking damages under the federal Consumer Products Safety Act); Heyn v. Braun, 239 Minn. 496 , 59 N.W.2d 326 (1953) (applying the relation back doctrine to a mechanic’s lien action).

21985–1999
Rugland v. Anderson green
minn · 1883
2 sentences

1999While both Regie and Gilliard find some support in a long line of cases beginning with Rugland v. Anderson, 30 Minn. 386 , 15 N.W. 676 (1883), where we established that adherence to the statute of limitations is a condition precedent to maintaining a wrongful death claim, I fail to see how prohibiting application of the relation back doctrine to wrongful death claims necessarily flows from those earlier eases.

1999While both Regie and Gilliard find some support in a long line of cases beginning with Rugland v. Anderson, 30 Minn. 386 , 15 N.W. 676 (1883), where we established that adherence to the statute of limitations is a condition precedent to maintaining a wrongful death claim, I fail to see how prohibiting application of the relation back doctrine to wrongful death claims necessarily flows from those earlier eases.

11999–1999
Nelson v. Glenwood Hills Hospitals, Inc. green
minn · 1953
2 sentences

1999See, e.g., Carlson v. Hennepin County, 479 N.W.2d 50 (Minn.1992) (holding that an amendment changing the identity of the defendant to the party actually liable for the injuries could relate back to the date of original filing); Fore v. Crop Hail Management, 270 N.W.2d 13 (Minn.1978) (same); Nelson v. Glenwood Hills Hospitals, 240 Minn. 505 , 62 N.W.2d 73 (1953).

1999See, e.g., Carlson v. Hennepin County, 479 N.W.2d 50 (Minn.1992) (holding that an amendment changing the identity of the defendant to the party actually liable for the injuries could relate back to the date of original filing); Fore v. Crop Hail Management, 270 N.W.2d 13 (Minn.1978) (same); Nelson v. Glenwood Hills Hospitals, 240 Minn. 505 , 62 N.W.2d 73 (1953).

11999–1999
Fore v. Crop Hail Management green
minn · 1978
2 sentences

1999See, e.g., Carlson v. Hennepin County, 479 N.W.2d 50 (Minn.1992) (holding that an amendment changing the identity of the defendant to the party actually liable for the injuries could relate back to the date of original filing); Fore v. Crop Hail Management, 270 N.W.2d 13 (Minn.1978) (same); Nelson v. Glenwood Hills Hospitals, 240 Minn. 505 , 62 N.W.2d 73 (1953).

1999See, e.g., Carlson v. Hennepin County, 479 N.W.2d 50 (Minn. 1992) (holding that an amendment changing the identity of the defendant to the party actually liable for the injuries could relate back to the date of original filing); Fore v. Crop Hail Management, 270 N.W.2d 13 (Minn.1978) (same); Nelson v. Glenwood Hills Hospitals, 240 Minn. 505 , 62 N.W.2d 73 (1953).

11999–1999
Regie De L'Assurance Automobile Du Quebec v. Jensen green
minn · 1987
2 sentences

1999We acknowledged in Regie that the vast majority of other jurisdictions do allow the relation back doctrine to apply to wrongful death claims and then distinguished those cases by stating that they frequently involved “blameless errors”; i.e., the party seeking to amend the complaint was not at fault for the delay in bringing the action. 399 N.W.2d at 90 .

1999We acknowledged in Regie that the vast majority of other jurisdictions do allow the relation back doctrine to apply to wrongful death claims and then distinguished those cases by stating that they frequently involved "blameless errors"; i.e., the party seeking to amend the complaint was not at fault for the delay in bringing the action. 399 N.W.2d at 90 .

11999–1999
Leaon v. Washington County green
minn · 1986
1 sentence

1989Id. at 871 .

11989–1989

Statutes the citing opinions construe

MN § Minn. Stat. § 573.02 (6)

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 429 (1929–2026) CA 143 (1965–2025) IL 123 (1962–2026) TX 95 (1958–2025) AL 73 (1984–2026) MI 67 (1977–2026) FL 59 (1961–2025) CT 56 (1988–2023) NC 40 (1971–2025) IA 36 (1992–2026) MD 27 (1962–2022) ID 26 (1984–2018) MS 22 (1987–2018) NJ 22 (1975–2025) CO 18 (1966–2016) LA 18 (1985–2023) PA 17 (1971–2025) OK 16 (1964–2017) UT 16 (1925–2025) GA 16 (1933–2026) MA 15 (1961–2020) MO 15 (1977–2023) OH 14 (1962–2024) WA 13 (1978–2021) IN 12 (1990–2026) TN 12 (1994–2026) MN 9 (1985–2012) DE 9 (1997–2025) NE 8 (1994–2023) MT 8 (1929–2026) AK 8 (1985–2021) OR 7 (1964–2016) NM 7 (1981–2013) AZ 6 (1981–2016) SD 6 (1994–2018) KY 6 (2005–2026) AR 6 (2003–2025) NV 6 (1993–2016) WY 6 (2004–2021) VA 5 (2003–2026) KS 5 (1977–2018) DC 4 (1977–2019) WV 4 (1990–2020) VT 3 (2006–2026) WI 3 (2010–2016) VI 3 (2012–2015) RI 3 (1995–2010) ND 2 (2004–2004) HI 2 (2005–2006)

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.

← Caselaw search · G Cite Topics · Brief Check