Legal Memorandum: Law of the Case Doctrine in MN

Issue: Whether evidence challenging the reasonableness of property division may be brought in a divorce action in Minnesota.

Minnesota law favors the finality of judgments, and seeks to achieve orderly processes by allowing parties to rely on the certainty of court orders.  Kansas City S. Ry. v. Great Lakes Carbon Corp., 624 F.2d 822, 825-26 (8^th Cir. 1980); accord Restatement (Second) of Judgments §12, cmt. d.  Even an “excessive” property award generally cannot be collaterally attacked in a subsequent proceeding.  E.g., Taylor v. Taylor, 413 N.W.2d 587, 589 (Minn. Ct. App. 1987).  In Greer v. Greer, 350 N.W.2d 439 (Minn. Ct. App. 1984), for instance, the court held that the final judgment and decree of marriage dissolution could not be collaterally attacked in subsequent quiet title action.  The court explained that “[t]he judgment and decree of marriage dissolution . . . was a final judgment.  There was no showing that it was invalid on its face.  Being valid on its face, it is not subject to collateral attack.”  Id. at 441 (citing Fidelity & Deposit Co. v. Riopelle, 298 Minn. 417, 421, 216 N.W.2d 674, 677 (1974)).

In addition, the law of the case doctrine prevents the relitigation of a settled issue in a case and requires courts to adhere to decisions made in earlier proceedings.  Mosley v. City of Northwoods, 415 F.3d 908, 911(8^th Cir. 2005).  This doctrine provides, in general, that a decision on an issue made by a court at one stage of a case should be given effect in successive […]