The old adage, “Fool me once, shame on you. Fool me twice, shame on me…,” comes to mind in the Minnesota Court of Appeals decision that came down yesterday in Collins v. Waconia Dodge, out of Carver County, where the case was tried before District Judge Philip T. Kanning.
Plaintiff Collins brought a claim against a business, family-owned and operated by his ex-wife and her family. Defendant moved for summary judgment, a motion it lost, but Judge Kanning, after a short bench trial, concluded that the plaintiff’s case was spurious and in the nature of an ex-spouse vendetta. On that basis, Judge Kanning levied significant sanctions against the plaintiff.
The issue on appeal was, in essence, the plaintiff arguing, “How could my claim be frivolous, spurious, and sanctionable but, yet, the Court denied defendant’s motion for summary judgment? Didn’t the Court itself find the claim sufficiently meritorious to withstand a summary judgment motion?”
A narrow reading of Judge Natalie Hudson‘s published opinion for the Minnesota Court of Appeals would emphasize that the summary judgment decision was focused solely on issues of service of the lawsuit and the statute of limitation, not evidence of the substantive claims.
A broader reading would suggest that a district court may give a litigant leeway or the benefit of the doubt when facing a motion for summary judgment but could still hold him accountable down the line if it were to turn out at trial that his claim was truly devoid of legal and/or factual bases.