Minnesota Statutes

Minn. Stat. § 580.19 (2026)

Certificate As Evidence

✓ current as of May 2026
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Every sheriff's certificate of sale made under a power to sell contained in a mortgage shall be prima facie evidence that all the requirements of law in that behalf have been complied with, and prima facie evidence of title in fee thereunder in the purchaser at such sale, the purchaser's heirs or assigns, after the time for redemption therefrom has expired.

Notes of Decisions
Cited in 24 cases, 1986–2016 · leading case: Fed. Home Loan Mortg. Corp. v. Gary E. Mitchell, John Doe, 862 N.W.2d 67 (Minn. Ct. App. 2015).
Fed. Home Loan Mortg. Corp. v. Gary E. Mitchell, John Doe, 862 N.W.2d 67 (Minn. Ct. App. 2015). · cites it 4× “en any sale of real property is made under a power of sale contained in any mortgage, the officer shall make and deliver to the purchaser a certificate” and, after the certificate has been recorded and the redemption period has expired, it “shall operate as a conveyance to the…”
Stein v. Chase Home Fin., LLC, 662 F.3d 976 (8th Cir. 2011). · cites it 2× “See Minn.Stat. § 580.19 (“Every sheriffs certificate of sale .”
Gerdin v. Princeton State Bank, 384 N.W.2d 868 (Minn. 1986). · cites it 2× “” Minn.Stat. § 580.19 (1984). Failure to serve notice of foreclosure on the government results in the purchaser, at the foreclosure sale, taking subject to the formerly junior tax liens.”
Newman v. JP Morgan Chase Bank, N.A., 81 F. Supp. 3d 735 (D. Minnesota 2015). · cites it 2× “See Minn.Stat. § 580.19. Plaintiff stated no facts in his Complaint to rebut this evidence and there is no evidence that Chase was not entitled to foreclose on the Mortgage.”
Arzt v. Bank of Am., N.A., 883 F. Supp. 2d 792 (D. Minnesota 2012). · cites it 2× “5; see Minn.Stat. § 580.19 (“Every sheriffs certificate of sale made under a power to sell contained in a mortgage shall be prima facie evidence that all the requirements of law in that behalf have been complied with.”
U. S. Bank Nat'l Ass'n, as Tr. for the Structured Asset Inv. Loan Trust, 2005-9 v. Maria Twigg (Minn. Ct. App. 2014). · cites it 6× “Minn. Stat. § 580.19 (2012). Twigg argues that Minn.”
Prime Sec. Bank v. A&G Investments, Inc. (Minn. Ct. App. 2015). · cites it 6× “12 (2014) and Minn. Stat. § 580.19 (2014) for support. Pertinent parts of section 580.”
Fed. Home Loan Mortg. Corp. v. Renee C. Kinzer, John Doe (Minn. Ct. App. 2015). · cites it 4× “” Minn. Stat. § 580.19 (2014). “The person entitled to the premises may recover possession by eviction when .”
Fed. Home Loan Mortg. Corp. v. Patricia G. Mikelson (Minn. Ct. App. 2015). · cites it 4× “Minn. Stat. § 580.19 (2014). The person entitled to the premises has the right to recover possession by eviction after the expiration of the time for redemption.”
Nationstar Mortg., LLC v. Julie Quale, John Doe (Minn. Ct. App. 2015). · cites it 4× “Minn. Stat. § 580.19 (2014). The person entitled to the premises has the right to recover possession by eviction after the expiration of the time for redemption.”
Fed. Nat'l Mortg. Ass'n v. Gretchen R. L. Harvey, Gerald Von Grewe (Minn. Ct. App. 2015). · cites it 4× “Minn. Stat. § 580.19 (2014). Fannie Mae holds the sheriff’s certificate of sale, which is prima facie evidence of title in fee.”
Nationstar Mortg., LLC v. Shawn R. Dooling, Bruce Polikowsky v. Caeasar Inv., LLC, (Intervenor). (Minn. Ct. App. 2016). · cites it 2× “5 Minn. Stat. § 580.19 (2014). Polikowsky’s bare assertion that Nationstar assigned its interest before commencing the eviction action is insufficient to rebut Nationstar’s prima facie evidence of title.”
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