Scenario: Minnesota Law (w/ Case Briefs, Statute Explanation, and Table of Authorities)
Scenario
The managing partner at your Minnesota law firm wants you to research and provide information concerning a minor’s lack of capacity to enter into a binding contract. She wants you to locate the following three Minnesota cases, as well as a fourth Minnesota case on the matter. 1. Ramsey Cnty. v. Guardian Ad Litem, 853 N.W.2d 813 (Minn. Ct. App. 2014). 2. Winter v. Skoglund, 404 N.W.2d 786 (Minn. 1987). 3. O'Brien Ent. Agcy. v. Wolfgramm, 407 N.W.2d 463 (Minn. Ct. App. 1987). She also wants you to locate the following two statutes and explain what a defendant is required to demonstrate concerning a minor’s lack of capacity. 1. MINN. STAT. ANN. § 645.45 (West 2016). 2. MINN. STAT. ANN. § 524.2-501 (West 2016). After you have located those four cases and two statutes, please provide one case brief for each case, for a total of four case briefs. Also, please provide an explanation for each statute.
Minnesota Case Briefs and
Statute Breakdown
Citation:
Ramsey Cnty. v. Guardian ad Litem X.L., 853 N.W.2d 813 (Minn. Ct. App. 2014)
Facts:
Ramsey
County challenges a child support magistrate's dismissal of two parentage
actions involving minors who signed “recognition of parentage” documents. The
magistrate explained that dismissal of the paternity actions was appropriate
because the fathers were listed on the child's birth certificates and that the
third sentence in section 257.75, subdivision 3 (regarding the effect of a
signed “recognition of parentage”), prohibited the court from ruling on the
issue of paternity.
Procedural
History:
Ramsey
County District Court rules in favor of defendants. Afterwards, Ramsey County
challenges decision and takes the issue to the appellate court.
Issue:
Do Minnesota
Statutes prevent a district court from deciding paternity when a minor signs
and files a “recognition of parentage” and no other evidence of paternity exist,
and does the subsequent appearance of the minor father's name on a birth
certificate prove the father-child relationship?
Rule:
No.
Minnesota law does not prevent a district court from deciding paternity when a
person under the age of 18 has signed a “recognition of parentage,” and the
birth certificate alone does not necessarily establish paternity.
Analysis:
The
Minnesota Parentage Act and Minnesota Statues section 257.75 allows courts to determine
parentage actions when a minor signs a “recognition of parentage.”
Conclusion:
The child support magistrate's
dismissal of the paternity actions is reversed and remand for further
proceedings
Citation:
Winter v. Skoglund, 404 N.W.2d 786 (Minn. 1987)
Facts:
Max
Winter, his three daughters, and PJ Acquisition Corporation brought a
declaratory judgment action to establish the invalidity of a March 21, 1984, contract,
which intended to subject Winter's Class B voting stock of Vikings II, Inc., to
a right of first refusal. The defendants, Vikings II, Inc., and the other
holders of legal or beneficial interests in Vikings II, Inc., Class B voting
stock, counterclaimed. They wanted specific enforcement of the rights of first
refusal provided in both the March 21, 1984, and in a December 1977 agreement.
Procedural
History:
Trial
court ruled in favor of Plaintiff, and dismissed post-trial actions made by
defendant. Afterwards, the defendants appealed and brought the case to the
appellate court.
Issue:
Did
either of the agreements, 1984 or 1977, subject Winter's voting shares of
Vikings II to a right of first refusal?
Rule:
No. The
agreements did not subject Winter’s shares.
Analysis:
There
was no contract for a right of first refusal made on March 21, 1984, because of
the absence of the mutual assent essential to form a contract. A contract may
become void on the grounds of mutual mistake if the party seeking to void the
contract did not assume the risk of the mistake. Skoglund and Winter were
mutually mistaken about a basic assumption that had a material effect on the
agreed-upon exchange and neither assumed the risk of this mistake. The contract
is, therefore, voidable.
Conclusion:
Appellate court affirmed the
decision of the trial court.
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Citation:
O'Brien Entertainment Agcy. v. Wolfgramm, 407 N.W.2d 463 (Minn. Ct. App. 1987)
Facts:
This
litigation stems from a 1983 general services agreement between a performing
artists booking agency, O'Brien Entertainment Agency, Inc., and a family
musical group now known as the "Jets". The
band consists of eight children; six are children of Michael and Vake
Wolfgramm, the other two children are cousins of the Wolfgramm children. The
booking agency is seeking damages resulting from an alleged breach of a 1983
personal services contract between O'Brien and the musical group.
Procedural
History:
A
summary judgement by the district court was granted in favor of the Wolfgramm
family. However, the booking agency appealed.
Issue:
Did the
district court err by granting summary judgment in favor of the musical group?
Rule:
Partially.
Analysis:
The
O'Brien contract is not enforceable against the Wolfgramm children simply because
none of the Wolfgramm children signed the April 1983 agreement and it therefore
does not comport with the statute of frauds. While the record indicates that
Vake was involved in the discussions preliminary to the contract signing, she
is not individually identified on the contract, and she did not sign the
agreement. The contract is not enforceable against her. It is believed the
district court erred by granting summary judgment in favor of Michael. Michael
did sign the agreement. We believe there are disputed material facts as to
whether he understood the terms and implications of the contract which do
relate to his personal liability under the contract.
Conclusion:
Reversal of the district court's summary judgment in favor of Michael Wolfgramm individually and remand for further findings on his personal liability under the April 1983 contract. Affirmed in part, reversed in part and remanded.
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Citation:
Kelly, Jr. v. Furlong, 194 Minn. 465, 261 N.W. 460 (Minn. 1935)
Facts:
This is
a suit to disaffirm and to rescind certain transactions had between plaintiff
and this defendant during plaintiff's infancy. Defendant is a stockbroker. Plaintiff
here is seeking to disaffirm his contracts solely upon the ground that he was
an infant at the time of entering into them.
Procedural
History:
District
court rules in favor of defendant, stockbroker. Plaintiff appealed from an
order denying his alternative motion for judgment or a new trial.
Issue:
Is the
plaintiff entitled financial recovery due to losses from depreciation in
stocks, because of his state of infancy at the time of the transaction?
Rule:
No.
Analysis:
The
court instructed the jury that plaintiff, though he had a right to disaffirm
these transactions upon becoming of age, was bound to exercise this right
within a reasonable time. If a contract, voidable by the infant is fully
executed, the infant must disaffirm within a reasonable time after reaching his
adulthood, or not at all. The infant is required to take some affirmative
action. Mere silence on his part will constitute a confirmation after the lapse
of a reasonable time.
Conclusion:
Appellate court affirms the decision of the district court.
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Minnesota statutes, chapter 645, covers the “Interpretation of Statutes and Rules.” More specifically, chapter 645 section 45, is a continuation of definitions of words and phrases, when used in any law enacted after the effective date of Laws 1941, chapter 492, section 45, unless the context clearly indicates otherwise. Some of these definitions include descriptions of who constitutes as an “adult,” “child,” or “minor” (i.e., "minor" means an individual under the age of 18 years).
Minnesota statutes, chapter 524, covers “Uniform Probate Code.” Further, article 2, “Intestate Succession and Wills,” part 5, “Wills,” describes the qualifications in which someone may make a will. According to Minnesota statute, “Any person 18 or more years of age who is of sound mind may make a will.”
TABLE OF AUTHORITIES
Page(s)
Cases
Statutes
MINN. STAT. ANN. §§ 645.45.................................................................................................................
6
MINN. STAT. ANN. §§ 524.2-501............................................................................................................
6
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