Legal Memorandum: Summary Judgment Standard in MN

Issue: What is the summary judgment standard and what is its purpose in Minnesota?

Summary judgment should be granted if the pleadings, the record in the case, and any supporting affidavits show that there is no genuine issue as to any material fact and that a party is entitled to judgment as a matter of law.  Minn. R. Civ. P. 56.03; DLH, Inc. v. Russ, 566 N.W.2d 60, 69 (Minn. 1997).  The purpose of summary judgment is to secure the just, speedy, and inexpensive determination of an action, “by allowing a court to dispose of an action on the merits if there is no genuine dispute regarding the material facts, and a party is entitled to judgment under the law applicable to such facts.”  DLH, Inc., 566 N.W.2d at 69; Sauter v. Sauter, 244 Minn. 482, 484-85, 70 N.W.2d 351, 353 (1955).  Summary judgment is a suitable vehicle for addressing the application of law to undisputed facts.  See, e.g., Anderson v. Christopherson, 816 N.W.2d 626, 630 (Minn. 2012); A.J. Chromy Constr. Co. v. Commercial Mech. Services, Inc., 260 N.W.2d 579, 581 (Minn. 1977).  To survive summary judgment, the non-moving party must point to specific evidence that would permit reasonable persons to draw different conclusions.  Gradjelick v. Hance, 464 N.W.2d 225, 231 (Minn. 2002).

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