Motion to Reconsider/Vacate (Summary Judgment) in Minnesota

Background

“Minn.R.Gen.Pract. 115.11 prohibits motions for reconsideration except by express permission of the court, which will be granted only upon a showing of compelling circumstances." (See Swanson v. Minnesota Fair Plan, No. CX-01-1994, at *1 (Minn. Ct. App. May 7, 2002).)

General Information for Complaints and Motions

“The district court is likely to exercise its discretion to reconsider a prior ruling only where intervening legal developments have occurred or where the earlier decision is palpably wrong in some respect.” (See Swanson v. Minnesota Fair Plan, No. CX-01-1994, at *1 (Minn. Ct. App. May 7, 2002).)

“A party seeking relief from a default judgment must demonstrate:

1. reasonable [claim] on the merits;
2. that there exists a reasonable excuse for failure or neglect to act;
3. that the party acted with due diligence after notice of the entry of judgment; and
4. that no substantial prejudice will result if the action is reopened.”

(See MEYER v. HEIN, No. C6-97-979, at *1 (Minn. Ct. App. Jan. 13, 1998).)

Standard of Review and Burdens of Proof

“The district court has discretion to hear a motion for reconsideration, and this court will not reverse unless it is shown that the district court abused its discretion.” (See Swanson v. Minnesota Fair Plan, No. CX-01-1994, at *1 (Minn. Ct. App. May 7, 2002).)

“The district court [also] has discretion to decide a motion to vacate a default judgment, and its decision will not be reversed absent an abuse of discretion.” (See MEYER v. HEIN, No. C6-97-979, at *1 (Minn. Ct. App. Jan. 13, 1998).)

The Court’s Decisions

It is well settled that “the district court may relieve a party from a final judgment based on [m]istake, inadvertence, surprise, or excusable neglect.” (See MEYER v. HEIN, No. C6-97-979, at *1 (Minn. Ct. App. Jan. 13, 1998).)

It is also well settled that “motions for reconsideration are not opportunities for presentation of facts or arguments available when the prior motion was considered and they will not be allowed to 'expand' or 'supplement' the record on appeal.” (See Terling Heights, LLC v. Veit, A12-0889, at *8 n.2 (Minn. Ct. App. Dec. 3, 2012).)