Minnesota Statutes
Minn. Stat. § 555.08 (2026)
Supplemental Relief
✓ current as of May 2026
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Further relief based on a declaratory judgment or decree may be granted whenever necessary or proper. The application therefor shall be by petition to a court having jurisdiction to grant the relief. If the application be deemed sufficient, the court shall, on reasonable notice, require any adverse party whose rights have been adjudicated by the declaratory judgment or decree, to show cause why further relief should not be granted forthwith.
Notes of Decisions
Cited in 20
cases, 1985–2018 · leading case: Garrick v. Northland Ins. Co., 469 N.W.2d 709 (Minn. 1991).
Garrick v. Northland Ins. Co., 469 N.W.2d 709 (Minn. 1991). “We find, therefore, that the policy limit of Northland’s uninsured motorists provision can be multiplied and affirm the court of appeals’ holding as to that issue.”
Kline v. Hanover Ins. Co., 368 N.W.2d 381 (Minn. Ct. App. 1985). “Did the trial court err in granting Kline’s motion for attorneys’ fees under Minn.Stat. § 555.08 (1982)? ANALYSIS I Hanover’s sole argument is that Kline is not covered since his car was not described in schedule A-125.”
In Re Silicone Implant Ins. Coverage Litig., 667 N.W.2d 405 (Minn. 2003). “Here, although the insurers did not have a duty to defend and there is not a relevant statute authorizing an award of attorney fees, the district court nevertheless granted 3M reasonable attorney fees based on the court’s finding that the insurers breached their implied covenant…”
Wood Goods Galore, Inc. v. Reinsurance Ass'n of Minnesota, 478 N.W.2d 205 (Minn. Ct. App. 1991). “Following trial, the court concluded Wood Goods was entitled to $80,000 in coverage for personal property loss; to coverage for business interruption loss at its retail store in Rochester, Minnesota, but not from its store in LaCrosse, Wisconsin; and to reasonable attorney fees…”
Wondra v. Am. Fam. Ins. Grp., 432 N.W.2d 455 (Minn. Ct. App. 1988). “The Declaratory Judgment Act contains a provision for supplemental relief; it provides that further relief based on a declaratory judgment or decree may be granted whenever necessary or proper.”
Peterson v. Wilson Twp., 672 N.W.2d 556 (Minn. 2003). “Further, the court of appeals rejected Peterson’s request for supplemental relief under Minn.Stat. § 555.08 (2000). This appeal followed.”
Am. Stand. Ins. Co. v. Le, 551 N.W.2d 923 (Minn. 1996). “” Ruling that Minn.Stat. § 555.08 (1990) could not be extended to provide for attorney fees absent a breach of the contractual duty to defend, we reversed the court of appeals’ award of attorney fees.”
In Re Silicone Implant Ins. Coverage Litig., 652 N.W.2d 46 (Minn. Ct. App. 2002). “1991) (overruling line of cases finding authority in Uniform Declaratory Judgments Act, Minn.Stat. § 555.08 (1990), to award fees in any coverage dispute); Olsen v.”
Spicer, Watson & Carp v. Minnesota Lawyers Mut. Ins. Co., 502 N.W.2d 400 (Minn. Ct. App. 1993). “See Minn.Stat. § 555.08 (1988). The supreme court indirectly reversed Wondra in Garrick v.”
Casey v. State Farm Mut. Auto. Ins. Co., 464 N.W.2d 736 (Minn. Ct. App. 1991). “Minn.Stat. § 555.08 (1988). Attorney fees are properly awarded in a declaratory judgment action as consequential damages for the insurer’s breach of contract.”
Higgins v. J.C. Penney Cas. Ins. Co., 413 N.W.2d 189 (Minn. Ct. App. 1987). “See Minn.Stat. § 555.08 (1986) (“Further relief based on a declaratory judgment * * * may be granted whenever necessary or proper”).”
Weber v. Sentry Ins., 442 N.W.2d 164 (Minn. Ct. App. 1989). “Minn. Stat. § 555.08 (1988) provides that a court may order supplemental relief in a declaratory judgment action whenever necessary or proper.”
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