Supreme Court Digest: Feb. 26, 2025

Listen to this article

Civil

Municipalities

Tort Liability

Appellant minor, by and through his mother and natural guardian, brought several tort claims against multiple parties—including a claim for negligent hiring against respondent school—after his teacher, defendant, sexually assaulted him. School sought summary judgment on minor’s claim under the discretionary-function exception to municipal tort liability set forth in Minn. Stat. § 466.03, subd. 6. To invoke the discretionary-function exception, a municipality bears the burden of proving that the conduct challenged in the lawsuit involved weighing competing social, political, economic, or financial considerations. The District Court granted summary judgment in favor of school, reasoning that a municipality’s decision to hire an employee is always a planning-level policy decision shielded from tort liability—even absent any evidence that the municipality weighed competing policy considerations in making the decision. The Court of Appeals affirmed applying the same reasoning.

The Supreme Court held that (1) a municipality’s activity broadly labeled as a “hiring decision” is not categorically and necessarily a policy-level decision involving weighing competing economic, social, political, and financial considerations for purposes of the discretionary-function exception to municipal tort liability under Minn. Stat. § 466.03, subd. 6; (2) on summary judgment, the circumstances surrounding the respondent school’s decision to hire defendant as a teacher do not support the inference, without actual evidence, that respondent’s conduct in failing to investigate defendant’s background was conduct involving balancing competing economic, social, political, and financial considerations for purposes of the discretionary-function exception to municipal tort liability. Reversed and remanded.

A22-1236 Doe v. Best Acad. (Court of Appeals)

Taxation

Review

In this case, relator county asked the court to revisit its decision in Beuning Family LP v. County of Stearns, 817 N.W.2d 122 (Minn. 2012), which held that a Tax Court order denying a motion to dismiss a petition as untimely is not a final order under Minn. Stat. § 271.10, subd. 1, that is reviewable by petition for a writ of certiorari to this court. County’s request arose as part of its defense to a property tax petition brought by respondent challenging relator county’s assessment of seven years of deferred taxes that resulted from respondent’s sale of a golf course. Before the parties tried the merits of that question to the Tax Court, however, county moved to dismiss respondent’s tax petition for lack of jurisdiction, arguing that the petition was untimely. The Tax Court denied county’s motion to dismiss, holding that the petition was timely and that the Tax Court did have jurisdiction over the case. County filed a writ of certiorari seeking review of the Tax Court’s order.

The Supreme Court held that (1) under Beuning Family LP v. County of Stearns, 817 N.W. 2d 122 (Minn. 2012), an order of the Tax Court denying a motion to dismiss for lack of jurisdiction is not immediately appealable as a final order under Minn. Stat. § 271.10, subd. 1; and (2) the interests of justice do not require the exercise of discretionary review under Minn. R. Civ. App. P. 105.1, when there is no compelling reason for immediate appeal and allowing the Tax Court to resolve the merits of the case best serves judicial economy and does not impair the relator’s interests. Writ of certiorari dismissed.

A24-0170 County of Hennepin v. Hollydale Land LLC (Tax Court)