Minnesota Statutes

Minn. Stat. § 645.39 (2026)

Implied Repeal By Later Law

✓ current as of May 2026
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When a law purports to be a revision of all laws upon a particular subject, or sets up a general or exclusive system covering the entire subject matter of a former law and is intended as a substitute for such former law, such law shall be construed to repeal all former laws upon the same subject. When a general law purports to establish a uniform and mandatory system covering a class of subjects, such law shall be construed to repeal preexisting local or special laws on the same class of subjects. In all other cases, a later law shall not be construed to repeal an earlier law unless the two laws are irreconcilable.

Notes of Decisions
Cited in 11 cases, 1946–2014 · leading case: Alice Ann Staab v. Diocese of St. Cloud, 853 N.W.2d 713 (Minn. 2014).
Alice Ann Staab v. Diocese of St. Cloud, 853 N.W.2d 713 (Minn. 2014). · cites it 4× “710, 710 (1897); D-6 see also Minn. Stat. § 645.39 (2012) (providing that “a later law shall not be construed to repeal an earlier law unless the two laws are irreconcilable” or the later law “purports to be a revision of all laws upon a particular subject”).”
Miller v. Colortyme, Inc., 518 N.W.2d 544 (Minn. 1994). · cites it 2× “Under Minn.Stat. § 645.39 (1992), where a later law does not purport to establish an exclusive system covering an subject matter, a later law shall only be construed as impliedly repealing earlier laws on the same subject where the two laws are irreconcilable.”
Nordmarken v. City of Richfield, 641 N.W.2d 343 (Minn. Ct. App. 2002). · cites it 2× “See Minn.Stat. § 645.39 (2000) (stating that when a law purports to revise all laws on a particular subject, and is intended to substitute for such former law, such law shall be construed to repeal all former laws upon the same subject).”
Bradley v. First Nat. Bank of Walker, N.A., 711 N.W.2d 121 (Minn. Ct. App. 2006). · cites it 2× “Minn.Stat. § 645.39. UFA § 8 deals with a matter that is also the subject of UCC § 3-307.”
Heideman v. Metro. Airports Comm'n, 555 N.W.2d 322 (Minn. Ct. App. 1996). · cites it 2× “When a general law establishes a uniform and mandatory system covering a class of subjects, that law is construed to repeal pre-existing special laws on the same class of subjects.”
State v. Elam, 84 N.W.2d 227 (Minn. 1957). · cites it 2× “Section 645.39 states: “When a law purports to be a revision of all laws upon a particular subject, or sets up a general or exclusive system covering the entire subject matter of a former law and is intended as a substitute for such former law, such law shall be construed to…”
State Ex Rel. Bergin v. Washburn, 28 N.W.2d 652 (Minn. 1947). “…Minn. 583, 585 , 222 N. W. 285, 286 . Cf. 6 Dunnell, Dig. & Supp. § 8927, and cases under notes 20 and 21; M. S. A. § 645.39.”
Indep. Sch. Dist. No. 700 v. City of Duluth, 170 N.W.2d 116 (Minn. 1969). “With respect to the first point, the school district suggests that the legislature has established a clear principle on the subject of implied repeal by a later law in § 645.39, which provides: “When a law purports to be a revision of all laws upon a particular subject, or sets…”
State v. Roselawn Cemetery Assn., 108 N.W.2d 305 (Minn. 1961). “In determining whether there has been an implied repeal by later law, we are guided by § 645.39 which states: “When a law purports to be a revision of all laws upon a particular subject, or sets up a general or exclusive system covering the entire subject matter of a former law…”
Levasseur v. Minneapolis Street Ry. Co., 21 N.W.2d 522 (Minn. 1946). “The highway traffic regulation act, subsequently enacted by the legislature and which purports to be a general and systematic revision of all traffic laws, in the interest of attaining uniformity, is irreconcilable with § 16(3) of said ordinance pertaining to the same…”
In Re Petition Regarding Assignment of Judges in the Ninth Jud. Dist., 416 N.W.2d 450 (Minn. 1987). · cites it 2× “Minn.Stat. § 645.39. Section 487.191 does not purport to be a revision of all laws upon the administration of the trial courts.”
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