preemption analysis (Minnesota) · Go Syfert
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preemption analysis in Minnesota

45 Minnesota opinions name it 2 courts 1984–2019 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 (29)

CaseFollowedCited
State v. RMhgreen
minn · 2000 · cited in 3 Minnesota opinions naming this issue, 2007–2011
2 sentences

2009State v. R.M.H. provides little guidance in this case because the decision there to conduct a preemption analysis "rest[ed] heavily on the status of R.M.H. as a nonmember Indian.” 617 N.W.2d 55 , 63 (Minn.2000).

2009Given our precedent in Stone , it is enough for me to acknowledge that the MCT is a tribe and Davis is a member of that tribe. [9] State v. R.M.H . provides little guidance in this case because the decision there to conduct a preemption analysis "rest[ed] heavily on the status of R.M.H. as a nonmember Indian." 617 N.W.2d 55 , 63 (Minn.2000).

23
Mangold Midwest Co. v. Village of Richfieldgreen
minn · 1966 · cited in 3 Minnesota opinions naming this issue, 1993–2006
2 sentences

2006See Mangold Midwest Co. v. Village of Richfield, 274 Minn. 347, 356 , 143 N.W.2d 813, 819 (1966).

2006See Mangold Midwest Co. v. Village of Richfield, 274 Minn. 347, 356 , 143 N.W.2d 813, 819 (1966).

23
City of Morris v. Sax Investments, Inc.green
minn · 2008 · cited in 2 Minnesota opinions naming this issue, 2011–2017
2 sentences

2017See Kuhlman, 729 N.W.2d at 584 (explaining that the “compelling public safety considerations” that led to adoption of an ordinance governing red-light violations "are not relevant to a preemption analysis”); City of Morris, 749 N.W.2d at 13 ("[R]egardless of our view on the merits of [the municipality’s] policy arguments, we are bound to apply the policy decisions adopted by the Legislature....”). .

2011Because the pipeline routing statute contains a specific preemption clause, our analysis should focus on “the language of the statute.” City of Morris v. Sax Invs., Inc., 749 N.W.2d 1, 6-7 (Minn.2008) (stating the factors we consider when the Legislature has “impliedly declared” an area to be “a matter solely of state concern” and explaining that this analysis does not apply when a statute “contains specific language as to the extent of permissible municipal regulation” (citation omitted) (internal quotation marks omitted)).

22
Caplinger v. Medtronic, Inc.green
okwd · 2013 · cited in 2 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015Cal. Jan. 30, 2014) (holding that “premarket approval imposes federal requirements on the Infuse device regardless of off-label promotion or use” (emphasis added)); Caplinger v. Medtronic, Inc., 921 F. Supp. 2d 1206, 1218 (W.D.

2015Jan. 30, 2014) (holding that “premarket approval imposes federal requirements on the Infuse device regardless of off-label promotion or use” (emphasis added)); Caplinger v. Med-tronic, Inc., 921 F.Supp.2d 1206, 1218 (W.D.Okla.2013) (same).

22
Dahl v. Charles Schwab & Co., Inc.green
minn · 1996 · cited in 2 Minnesota opinions naming this issue, 1997–2002
2 sentences

2002Preemption analysis begins with the assumption that the “historic police powers of the [s]tates” are not to be eclipsed unless to do so was “the clear and manifest purpose of Congress.” Dahl v. Charles Schwab & Co., 545 N.W.2d 918, 922 (Minn.1996) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 , 67 S.Ct. 1146, 1152 , 91 L.Ed. 1447 (1947)).

2002Preemption analysis begins with the assumption that the "historic police powers of the [s]tates" are not to be eclipsed unless to do so was "the clear and manifest purpose of Congress." Dahl v. Charles Schwab & Co., 545 N.W.2d 918, 922 (Minn.1996) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 , 67 S.Ct. 1146, 1152 , 91 L.Ed. 1447 (1947)).

22
State v. Kuhlmangreen
minn · 2007 · cited in 2 Minnesota opinions naming this issue, 2013–2017
2 sentences

2017See Kuhlman, 729 N.W.2d at 584 (explaining that the “compelling public safety considerations” that led to adoption of an ordinance governing red-light violations "are not relevant to a preemption analysis”); City of Morris, 749 N.W.2d at 13 ("[R]egardless of our view on the merits of [the municipality’s] policy arguments, we are bound to apply the policy decisions adopted by the Legislature....”). .

2013State v. Kuhlman, 722 N.W.2d 1, 3-5 (Minn.App.2006), aff'd, 729 N.W.2d 577 (Minn.2007). 3 We adopt the same approach here.

12
California v. Cabazon Band of Mission Indiansred
scotus · 1987 · cited in 2 Minnesota opinions naming this issue, 1997–2004
2 sentences

2004State law is preempted by federal law in this context “if it interferes or is incompatible with federal and tribal interests reflected in federal law, unless the state interests at stake are sufficient to justify the assertion of state authority.” California v. Cabazon Band of Mission Indians, 480 U.S. 202, 216 , 107 S.Ct. 1083 , 94 L.Ed.2d 244 (1987) (quoting New Mexico v. Mescalero Apache Tribe, 462 U.S. 324, 333 , 103 S.Ct. 2378 , 76 L.Ed.2d 611 (1983)).

2004State law is preempted by federal law in this context “if it interferes or is incompatible with federal and tribal interests reflected in federal law, unless the state interests at stake are sufficient to justify the assertion of state authority.” California v. Cabazon Band of Mission Indians, 480 U.S. 202, 216 , 107 S.Ct. 1083 , 94 L.Ed.2d 244 (1987) (quoting New Mexico v. Mescalero Apache Tribe, 462 U.S. 324, 333 , 103 S.Ct. 2378 , 76 L.Ed.2d 611 (1983)).

12
Jennissen v. City of Bloomingtongreen
minn · 2018 · cited in 1 Minnesota opinions naming this issue, 2019–2019
1 sentence

2019See Jennissen , 913 N.W.2d at 460 .

11
In Re Consolidated Hospital Surcharge Appeals of GILLETTE CHILDREN’S SPECIALTY HEALTHCARE, St. Luke’s Hospital, North Memorial Health Care, HealthEast Care System, Park Nicollet Health Services, Fairview Health Services, and Children’s Hospitals and Clinics of Minnesotagreen
minn · 2016 · cited in 1 Minnesota opinions naming this issue, 2017–2017
1 sentence

2017The district court considered field preemption, express preemption, and conflict preemption, see In re Gillette Children's Specialty Healthcare, 883 N.W.2d 778, 785 (Minn. 2016) (explaining that preemption may be found “ ‘by express provision, by implication, or by a conflict' ” with other laws (quoting N.Y.

11
Howlett Ex Rel. Howlett v. Rosegreen
scotus · 1990 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015Howlett v. Rose, 496 U.S. 356, 372 , 110 S. Ct. 2430, 2441 (1990).

2015Howlett v. Rose, 496 U.S. 356, 372 , 110 S. Ct. 2430, 2441 (1990).

11
Grade v. BNSF Railway Co.green
ca8 · 2012 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014See Grade, 676 F.3d at 685 .

11
Morissette v. United Statesgreen
scotus · 1952 · cited in 1 Minnesota opinions naming this issue, 2013–2013
2 sentences

2013See Morissette v. U.S., 342 U.S. 246, 263 , 72 S.Ct. 240, 250 , 96 L.Ed. 288 (1952) (stating that when the legislature uses terms of art that have “accumulated the legal tradition and meaning of centuries of practice, it presumably knows and adopts the cluster of ideas that were attached to each borrowed word in the body of learning from which it was taken and the meaning its use will convey to the judicial mind”).

2013See Morissette v. U.S., 342 U.S. 246, 263 , 72 S.Ct. 240, 250 , 96 L.Ed. 288 (1952) (stating that when the legislature uses terms of art that have “accumulated the legal tradition and meaning of centuries of practice, it presumably knows and adopts the cluster of ideas that were attached to each borrowed word in the body of learning from which it was taken and the meaning its use will convey to the judicial mind”).

11
State v. Kuhlmangreen
minnctapp · 2006 · cited in 1 Minnesota opinions naming this issue, 2013–2013
1 sentence

2013State v. Kuhlman, 722 N.W.2d 1, 3-5 (Minn.App.2006), aff'd, 729 N.W.2d 577 (Minn.2007). 3 We adopt the same approach here.

11
State v. Davisgreen
minn · 2009 · cited in 1 Minnesota opinions naming this issue, 2011–2011
1 sentence

2011I reach this conclusion based on the preemption analysis we followed in State v. Davis, 773 N.W.2d 66, 69 (Minn.2009).

11
In Re the Estate of Barggreen
minn · 2008 · cited in 1 Minnesota opinions naming this issue, 2009–2009
1 sentence

2009“Congressional purpose is ‘the ultimate touchstone’ of the preemption inquiry.” In re Estate of Barg, 752 N.W.2d 52, 63 (Minn.2008) (quoting Malone v. White Motor Corp., 435 U.S. 497, 504 , 98 S.Ct. 1185, 1190 , 55 L.Ed.2d 443 (1978)).

11
State v. Stonegreen
minn · 1997 · cited in 1 Minnesota opinions naming this issue, 2009–2009
2 sentences

2009We held that, for a speeding violation, a preemption analysis was unnecessary because the state could not overcome “ ‘the right of reservation Indians to make them own laws and be ruled by them.’ ” Stone, 572 N.W.2d at 732 (quoting White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 142 , 100 S.Ct. 2578 , 65 L.Ed.2d 665 (1980)).

2009I believe that because this case is also a traffic violation case, our decision in Stone is controlling: “Without exceptional circumstances, we do not reach the preemption analysis.” Id.

11
Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, P. C.green
scotus · 1986 · cited in 1 Minnesota opinions naming this issue, 2009–2009
2 sentences

2009See 476 U.S. at 884 , 106 S.Ct. 2305 .

2009See 476 U.S. at 884 , 106 S.Ct. 2305 .

11
Cipollone v. Liggett Group, Inc.green
scotus · 1992 · cited in 1 Minnesota opinions naming this issue, 2007–2007
2 sentences

2007See Cipollone, 505 U.S. at 508-09 , 112 S.Ct. at 2614-15 . 2 In Cipollone , the Court considered whether the FCLAA’s preemption clause barred a state-law suit for damages brought by a smoker who had allegedly developed lung cancer from the defendants’ cigarettes.

2007See Cipollone, 505 U.S. at 508-09 , 112 S.Ct. at 2614-15 . 2 In Cipollone , the Court considered whether the FCLAA’s preemption clause barred a state-law suit for damages brought by a smoker who had allegedly developed lung cancer from the defendants’ cigarettes.

11
Minneapolis Term Limits Coalition v. Keefegreen
minn · 1995 · cited in 1 Minnesota opinions naming this issue, 2005–2005
11
Blackburn v. Doubleday Broadcasting Co.green
minn · 1984 · cited in 1 Minnesota opinions naming this issue, 2001–2001
11
American Airlines, Inc. v. Wolensgreen
scotus · 1995 · cited in 1 Minnesota opinions naming this issue, 2000–2000
11
cluster 759280green
ca9 · 1998 · cited in 1 Minnesota opinions naming this issue, 2000–2000
11
Shaw v. Delta Air Lines, Inc.green
scotus · 1983 · cited in 1 Minnesota opinions naming this issue, 1998–1998
11
State v. Stonegreen
minnctapp · 1997 · cited in 1 Minnesota opinions naming this issue, 1997–1997
11
CSX Transportation, Inc. v. Easterwoodgreen
scotus · 1993 · cited in 1 Minnesota opinions naming this issue, 1997–1997
11
National Aviation v. City of Hayward, Cal.green
cand · 1976 · cited in 1 Minnesota opinions naming this issue, 1994–1994
11
Liebsch v. Abbottgreen
minn · 1963 · cited in 1 Minnesota opinions naming this issue, 1990–1990
11
Silkwood v. Kerr-McGee Corp.green
scotus · 1984 · cited in 1 Minnesota opinions naming this issue, 1988–1988
11
Junior S. Jackson, Cross-Appellant v. Consolidated Rail Corporation, Cross-Appelleegreen
ca7 · 1984 · cited in 1 Minnesota opinions naming this issue, 1986–1986
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 (35)

CaseCitedYears
Rice v. Santa Fe Elevator Corp. green
scotus · 1947
2 sentences

2017A preemption analysis starts from the assumption “that ‘the historic police powers of the States’ are not superseded ‘unless that was the clear and manifest purpose of Congress.’ ” Arizona v. United States, 567 U.S. 387, 400 , 132 S.Ct. 2492 , 183 L.Ed.2d 351 (2012) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 , 67 S.Ct. 1146 , 91 L.Ed. 1447 (1947)).

2017A preemption analysis starts from the assumption “that ‘the historic police powers of the States’ are not superseded ‘unless that was the clear and manifest purpose of Congress.’ ” Arizona v. United States, 567 U.S. 387, 400 , 132 S.Ct. 2492 , 183 L.Ed.2d 351 (2012) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 , 67 S.Ct. 1146 , 91 L.Ed. 1447 (1947)).

41996–2017
New Mexico v. Mescalero Apache Tribe green
scotus · 1983
2 sentences

2004Preemption inquiry *150 should be performed with an eye towards “traditional notions of Indian sovereignty and the congressional goal of Indian self-government, including its ‘overriding goal’ of encouraging tribal self-sufficiency and economic development.” Id.

2000Further, in this area of the law, a preemption analysis rests “principally on a consideration of the nature of the competing interests at stake” and rejects “a narrow focus on congressional intent to preempt state law as the sole touchstone.” Mescalero, 462 U.S. at 334 , 103 S.Ct. 2378 .

32000–2004
Malone v. White Motor Corp. green
scotus · 1978
2 sentences

2009“Congressional purpose is ‘the ultimate touchstone’ of the preemption inquiry.” In re Estate of Barg, 752 N.W.2d 52, 63 (Minn.2008) (quoting Malone v. White Motor Corp., 435 U.S. 497, 504 , 98 S.Ct. 1185, 1190 , 55 L.Ed.2d 443 (1978)).

2009“Congressional purpose is ‘the ultimate touchstone’ of the preemption inquiry.” In re Estate of Barg, 752 N.W.2d 52, 63 (Minn.2008) (quoting Malone v. White Motor Corp., 435 U.S. 497, 504 , 98 S.Ct. 1185, 1190 , 55 L.Ed.2d 443 (1978)).

22008–2009
White Mountain Apache Tribe v. Bracker green
scotus · 1980
2 sentences

2009We held that, for a speeding violation, a preemption analysis was unnecessary because the state could not overcome “ ‘the right of reservation Indians to make them own laws and be ruled by them.’ ” Stone, 572 N.W.2d at 732 (quoting White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 142 , 100 S.Ct. 2578 , 65 L.Ed.2d 665 (1980)).

2009We held that, for a speeding violation, a preemption analysis was unnecessary because the state could not overcome “ ‘the right of reservation Indians to make them own laws and be ruled by them.’ ” Stone, 572 N.W.2d at 732 (quoting White Mountain Apache Tribe v. Bracker, 448 U.S. 136, 142 , 100 S.Ct. 2578 , 65 L.Ed.2d 665 (1980)).

21997–2009
Hines v. Davidowitz green
scotus · 1941
2 sentences

1988The Court *697 thus contrasted the preemption analysis of health and safety matters with the analysis in other areas, such as foreign affairs, where an intent to preempt can be “inferred * * * from the dominance of the federal interest * * *.” Id. at 719 , 105 S.Ct. at 2378 , citing Hines v. Davidowitz, 312 U.S. 52 , 61 S.Ct. 399 , 85 L.Ed. 581 (1941).

1988The Court *697 thus contrasted the preemption analysis of health and safety matters with the analysis in other areas, such as foreign affairs, where an intent to preempt can be “inferred * * * from the dominance of the federal interest * * *.” Id. at 719 , 105 S.Ct. at 2378 , citing Hines v. Davidowitz, 312 U.S. 52 , 61 S.Ct. 399 , 85 L.Ed. 581 (1941).

21988–1995
Arizona v. United States green
scotus · 2012
2 sentences

2017A preemption analysis starts from the assumption “that ‘the historic police powers of the States’ are not superseded ‘unless that was the clear and manifest purpose of Congress.’ ” Arizona v. United States, 567 U.S. 387, 400 , 132 S.Ct. 2492 , 183 L.Ed.2d 351 (2012) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 , 67 S.Ct. 1146 , 91 L.Ed. 1447 (1947)).

2017A preemption analysis starts from the assumption “that ‘the historic police powers of the States’ are not superseded ‘unless that was the clear and manifest purpose of Congress.’ ” Arizona v. United States, 567 U.S. 387, 400 , 132 S.Ct. 2492 , 183 L.Ed.2d 351 (2012) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 , 67 S.Ct. 1146 , 91 L.Ed. 1447 (1947)).

12017–2017
Ingersoll-Rand Co. v. McClendon green
scotus · 1990
2 sentences

2015Id. at 138 , 111 S.Ct. 478 .

2015Id. at 138 , 111 S.Ct. 478 .

12015–2015
Barrientos v. 1801-1825 MORTON LLC green
ca9 · 2009
1 sentence

2014This case therefore resembles Barrientos v. 1801-1825 Morton LLC, in which the Ninth Circuit rejected a preemption challenge to a Los Angeles ordinance that gave tenants in federally subsidized housing greater protection from eviction than did federal law. 583 F.3d 1197 (9th Cir.2009).

12014–2014
Retail Clerks International Ass'n, Local 1625 v. Schermerhorn green
scotus · 1963
2 sentences

2008Malone v. White Motor Corp., 435 U.S. 497, 504 , 98 S.Ct. 1185 , 55 L.Ed.2d 443 (1978) (quoting Retail Clerks Int’l Ass’n, Local 1625 v. Schermerhorn, 375 U.S. 96, 103 , 84 S.Ct. 219 , 11 L.Ed.2d 179 (1963)).

2008Malone v. White Motor Corp., 435 U.S. 497, 504 , 98 S.Ct. 1185 , 55 L.Ed.2d 443 (1978) (quoting Retail Clerks Int’l Ass’n, Local 1625 v. Schermerhorn, 375 U.S. 96, 103 , 84 S.Ct. 219 , 11 L.Ed.2d 179 (1963)).

12008–2008
cluster 741155 green
ca3 · 1997
1 sentence

2008Bucholtz, 114 F.3d at 924 .

12008–2008
State v. Hoben green
minn · 1959
12007–2007
Oklahoma Tax Commission v. Sac & Fox Nation green
scotus · 1993
12007–2007
Lorillard Tobacco Co. v. Reilly green
scotus · 2001
2 sentences

2007Id. at 546 , 121 S.Ct. at 2417 .

2007Id. at 546 , 121 S.Ct. at 2417 .

12007–2007
City of St. Paul v. Olson green
minn · 1974
2 sentences

2007In Olson , the defendant, charged with violating a Saint Paul ordinance prohibiting unreasonable acceleration, challenged the ordinance on the ground that it conflicted with state law. 300 Minn. at 455-56 , 220 N.W.2d at 484-85 .

2007In Olson , the defendant, charged with violating a Saint Paul ordinance prohibiting unreasonable acceleration, challenged the ordinance on the ground that it conflicted with state law. 300 Minn. at 455-56 , 220 N.W.2d at 484-85 .

12007–2007
Avemco Insurance Co. v. State Ex Rel. McCarty green
indctapp · 2004
12006–2006
Hubsch v. United States green
scotus · 1950
12004–2004
Harker v. University Professionals of Illinois green
scotus · 1999
12001–2001
Head v. New Mexico Board of Examiners in Optometry green
scotus · 1963
12001–2001
Duro v. Reina red
scotus · 1990
12000–2000
Morales v. Trans World Airlines, Inc. green
scotus · 1992
12000–2000
Wyshak v. American Savings Bank, F.A. green
scotus · 1996
11997–1997
Florida Lime & Avocado Growers, Inc. v. Paul green
scotus · 1963
11995–1995
cluster 584519 green
ca3 · 1992
11995–1995
Fidelity Federal Savings & Loan Ass'n v. De La Cuesta green
scotus · 1982
11995–1995
Chicago & North Western Transportation Co. v. Kalo Brick & Tile Co. green
scotus · 1981
11995–1995
Maryland v. Louisiana green
scotus · 1981
11995–1995
San Diego Unified Port District v. Gianturco green
casd · 1978
11994–1994
National Labor Relations Board v. Insurance Agents' International Union green
scotus · 1960
11994–1994
Lodge 76, International Ass'n of MacHinists & Aerospace Workers v. Wisconsin Employment Relations Commission green
scotus · 1976
11994–1994
National Labor Relations Board v. Nash-Finch Co. green
scotus · 1971
11994–1994
Belknap, Inc. v. Hale green
scotus · 1983
11994–1994
Hillsborough County v. Automated Medical Laboratories, Inc. green
scotus · 1985
11988–1988
Farmer v. United Brotherhood of Carpenters & Joiners of America, Local 25 green
scotus · 1977
11985–1985
Local 100, United Ass'n of Journeymen & Apprentices v. Borden green
scotus · 1963
11984–1984
Northern States Power Co. v. Hagen green
nd · 1981
11984–1984

Statutes the citing opinions construe

MN § Minn. Stat. § 645.16 (8) USC § 18u.s.c.1162 (8) MN § Minn. Stat. § 116.07 (4) MN § Minn. Stat. § 169.022 (3) MN § Minn. Stat. § 645.08 (3) USC § 28u.s.c.1360 (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

CA 277 (1911–2026) NY 112 (1981–2026) IL 101 (1974–2026) TX 93 (1969–2025) NJ 69 (1971–2026) PA 66 (1966–2025) OH 50 (1975–2026) MN 45 (1984–2019) TN 45 (1987–2022) IN 38 (1981–2024) MI 35 (1970–2025) CO 32 (1972–2025) WA 32 (1972–2021) NM 31 (1987–2019) WI 31 (1980–2025) AZ 30 (1971–2025) IA 30 (1978–2026) MD 29 (1977–2026) MA 27 (1964–2023) FL 24 (1962–2021) LA 23 (1962–2024) OK 20 (1986–2024) GA 19 (1991–2022) MO 19 (1971–2017) AL 17 (1964–2014) MT 16 (1977–2025) KS 16 (1922–2026) OR 14 (1985–2023) NV 14 (2000–2026) SC 13 (1984–2019) NC 13 (1973–2026) NH 13 (1995–2019) CT 12 (1990–2024) HI 12 (1982–2023) UT 11 (1992–2012) NE 10 (1982–2006) KY 10 (1979–2026) MS 9 (1968–2013) ID 9 (1979–2018) AK 8 (1967–2022) DE 8 (1980–2025) WV 7 (2009–2024) VT 7 (1988–2024) RI 7 (1985–2020) ME 6 (1989–2025) AR 5 (1984–2025) ND 5 (1991–2025) VA 5 (1985–2021) VI 4 (2010–2026) SD 4 (1977–2020) DC 3 (1986–2009) WY 2 (2014–2014) PR 2 (2023–2025)

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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