Minnesota Statutes

Minn. Stat. § 645.21 (2026)

Presumption Against Retroactive Effect

✓ current as of May 2026
Find cases: SyfertCases citing this section MN-REVrevisor.mn.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

No law shall be construed to be retroactive unless clearly and manifestly so intended by the legislature.

Notes of Decisions
Cited in 161 cases (3 in the last 5 years), 1945–2025 · leading case: Gomon v. Northland Fam. Physicians, Ltd., 645 N.W.2d 413 (Minn. 2002).
Gomon v. Northland Fam. Physicians, Ltd., 645 N.W.2d 413 (Minn. 2002). · cites it 20× “The second canon of statutory construction relevant to our analysis is set forth in Minn. Stat. § 645.21 (2000), which provides: No law shall be construed to be retroactive unless clearly and manifestly so intended by the legislature.”
Wschola v. Snyder, 478 N.W.2d 225 (Minn. Ct. App. 1991). · cites it 36× “Klimmek suggests that the application of a new statute of limitations to an existing cause of action is not a retroactive application, but other cases appear to analyze this as within Minn.Stat. § 645.21. See id. at 503. The supreme court declined to apply an expanded statute of…”
Rural Am. Bank of Greenwald v. Herickhoff, 485 N.W.2d 702 (Minn. 1992). · cites it 12× “1951); Minn.Stat. § 645.21 (1990); Minn.Stat. *707 § 645.”
State Ex Rel. Cooper v. French, 460 N.W.2d 2 (Minn. 1990). · cites it 4× “02 (1988); see also Minn.Stat. § 645.21 (1988) (presumption against retroactive effect).”
State v. Traczyk, 421 N.W.2d 299 (Minn. 1988). · cites it 12× “” Minn.Stat. § 645.21 (1986). In following that legislative mandate, we have held that before a statute will be afforded retroactive application, there must exist clear evidence that the legislature intended retroactive application “ * * * such as mention of the word…”
Gomon v. Northland Fam. Physicians, Ltd., 625 N.W.2d 496 (Minn. Ct. App. 2001). · cites it 16× “The narrow issue in this case is whether the four-year statute of limitations applies retroactively to revive a claim that was time-barred prior to August 1, 1999.”
Laue v. Prod. Credit Ass'n of Blooming Prairie, 390 N.W.2d 823 (Minn. Ct. App. 1986). · cites it 12× “[1] Minn.Stat. § 645.21. This court may "not give retroactive effect to a statute unless a purpose that it have such effect is implicit therein.”
Hodder v. Goodyear Tire & Rubber Co., 426 N.W.2d 826 (Minn. 1988). · cites it 4× “…not "clearly manifest" an intent to be applied retroactively, and we hold it does not have retroactive effect. See Minn.Stat. § 645.21 (1987).”
Carlson v. Lilyerd, 449 N.W.2d 185 (Minn. Ct. App. 1989). · cites it 8× “Under the current statutory language "only a family farmer, family farm corporation, or family farm partnership can be an immediately preceding former owner.”
Hunt v. Nevada State Bank, 172 N.W.2d 292 (Minn. 1969). · cites it 6× “One of our statutory canons of construction, § 645.21, provides: “No law shall be construed to be retroactive unless clearly and manifestly so intended by the legislature.”
In re Individual 35W Bridge Litig., 806 N.W.2d 811 (Minn. 2011). · cites it 6× “The court of appeals’ interpretation is erroneous because it ignores the presumption against retroactivity unless the statute “clearly and manifestly” demonstrates contrary legislative intent.”
Lovgren v. Peoples Elec. Co., Inc., 380 N.W.2d 791 (Minn. 1986). · cites it 6× “We hold that Lovgren’s claim was governed by the general 6-year period. Since Lovgren brought suit against Peoples Electric within 6 years of accrual, we reverse the court of appeals and the district court and remand the case for trial.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.