Justia Commercial Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Sorchaga v. Ride Auto, LLC
A seller’s fraudulent statements about the fitness of a vehicle for the purpose for which it was purchased make disclaimers in purchase documents stating that the buyer purchased the vehicle “as is” ineffective.The district court in this case awarded relief to the buyer on both fraud and breach of warranty theories. The Supreme Court affirmed, holding (1) the buyer’s fraudulent statements about the fitness of the vehicle being sold for the purpose for which the vehicle was purchased made the “as is” disclaimers of implied warranties in the purchase documents ineffective under Minn. Stat. 336.2-316(3)(a); and (2) under the Uniform Commercial Code, a party may seek remedies for fraud, including breach of warranty, even after the rescission of a purchase contract, and therefore, the district court did not err in awarding damages under both fraud and breach of an implied warranty theories of liability. View "Sorchaga v. Ride Auto, LLC" on Justia Law
City of Oronoco v. Fitzpatrick Real Estate, LLC
Whitney National Bank (Whitney) obtained a judgment against Daniel Fitzpatrick and his business entities (collectively, Fitzpatrick). In a separate matter, Fitzpatrick, represented by O’Brien & Wolf, LLP, obtained a judgment against the City of Oronoco. Whitney served a garnishment summons on the City to establish and perfect a garnishment lien against the judgment proceeds won by Fitzpatrick. O’Brien subsequently filed a motion to establish and determine the amount and priority of its attorney’s lien. The district court held that Whitney’s garnishment lien was superior to O’Brien’s attorney’s lien, concluding that a cause-of-action attorney’s lien is perfected, as against third parties, from the time the attorney files notice of the lien claim. The court of appeals reversed. The Supreme Court affirmed, holding that the plain language of Minn. Stat. 481.13(1)(a)(1) does not require an attorney with a cause-of-action attorney’s lien to file notice of the lien claim for the lien to have priority over third-party claims. View "City of Oronoco v. Fitzpatrick Real Estate, LLC" on Justia Law
Wayzata Nissan, LLC v. Nissan N. Am., Inc.
Nissan North America, Inc., a motor vehicle manufacturer, and Stephen McDaniels, a prospective Nissan dealer (collectively, Defendants), sought to relocate a Nissan dealership to a location 7.6 miles from a dealership operated by Wayzata Nissan, LLC. Wayzata filed an action against Defendants and then moved for a temporary restraining order, challenging the relocation under the Minnesota Motor Vehicle Sale and Distribution Act, Minn. Stat. 80E.01-.17. The district court denied the motion, determining that the exception in section 80E.14(1) for the “relocation of an existing dealer” applied. The court of appeals affirmed. The Supreme Court reversed on the merits, holding (1) even though the relocation at issue has already occurred this appeal is not moot; (2) the notice and good-cause requirements of section 80E.14(1) apply on the date that a manufacturer develops the intention to authorize a relocation, not on the date of the physical relocation of a dealership; and (3) the existing-dealer exception does not apply when the relocation of a dealership is accompanied by a change in the person or entity operating the dealership, and therefore, the existing-dealer exception does not apply in this case. View "Wayzata Nissan, LLC v. Nissan N. Am., Inc." on Justia Law