Legal Memorandum: Distinction Between Claim and Cause of Action

Issue: Under Minnesota law, is there a distinction between a claim and a cause of action?

“Claim” and “cause of action” are used interchangeably in various contexts.  See, e.g., St. Paul Fire & Marine Ins. Co. v. Compaq Computer Corp., 539 F.3d 809, 821 (8^th Cir. 2008) (stating, in res judicata context, that “Minnesota courts use the terms ‘claim’ and ’cause of action’ interchangeably”); Comsat Corp. v. St. Paul Mercury Ins. Co., No. Civ. 97–2236 **3-4 (D. Minn. Mar. 6, 1998) (also stating that “‘[c]ause of action’ and ‘claim’ are loosely defined terms, and have been interpreted as interchangeable by the Eighth Circuit: ‘A “cause of action” is a situation or state of facts which entitles a party to sustain an action and gives him the right to seek judicial interference in his behalf. 

Under the Federal Rules of Civil Procedure, the word “claim” denotes the same thing, i.e. “the aggregate of operative facts which give rise to a right enforceable in the courts.”) (citation omitted). 

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