Minnesota Statutes
Minn. Stat. § 645.21 (2026)
Presumption Against Retroactive Effect
✓ current as of May 2026
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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). “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). “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). “1951); Minn.Stat. § 645.21 (1990); Minn.Stat. *707 § 645.”
State Ex Rel. Cooper v. French, 460 N.W.2d 2 (Minn. 1990). “02 (1988); see also Minn.Stat. § 645.21 (1988) (presumption against retroactive effect).”
State v. Traczyk, 421 N.W.2d 299 (Minn. 1988). “” 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). “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). “[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). “…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). “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). “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). “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). “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.”
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