Legal Memorandum: Standard for Summary Judgment in MN

Issue: Under Minnesota law, what is the standard for summary judgment under Rule 56.03?

Area of Law: Litigation & Procedure
Keywords: Summary judgment; No genuine issue as to any material fact; Judgment as a matter of law
Jurisdiction: Minnesota
Cited Cases: 305 N.W.2d 337; 504 N.W.2d 758
Cited Statutes: Rule 56.03
Date: 03/01/2014

Under Rule 56.03 the initial burden is on the moving party to demonstrate that there is no genuine issue as to any material fact and that either party is entitled to judgment as a matter of law.  Martin v. Spirit Mountain, 566 N.W.2d 719, 721 (Minn. 1997); Thiele v. Stich, 425 N.W.2d 580, 583 (Minn. 1988) (“The party moving for summary judgment under Rule 56, Minn. R. Civ. P., must demonstrate no genuine issue of material fact exists”).  The evidence is viewed in light most favorable to the non-moving party.  Fabio v. Bellomo, 504 N.W.2d 758, 761 (Minn. 1993).

“The district court’s function on a motion for summary judgment is not to decide issues of fact, but solely to determine whether genuine factual issues exist.”  DLH, Inc. v. Russ, 566 N.W.2d 60, 70 (Minn. 1997); see Nord v. Herreid, 305 N.W.2d 337, 339 (Minn.1981).  “We reiterate that the court must not weigh the evidence on a motion for summary judgment.”  DLH, Inc., 566 N.W.2d at 70.  In Nicollet Restoration, Inc. v. City of St. Paul, the court held that a moving party is entitled to summary judgment only when “there are no facts in the record giving rise to a genuine issue for trial as to the existence of an essential element of the nonmoving party’s case.”  533 N.W.2d 845, 847-48 (Minn. 1995) (citing Celotex Corp. v. Catrett,
477 U.S. 317, 322 (1986).