Motion to Dismiss For Failure to State a Claim in Minnesota

Background

“Motions to dismiss under rule 12.02 for failure to state a claim upon which relief can be granted test only the sufficiency of the pleadings.” (See Schuler v. Meschke (1989) 435 N.W.2d 156, 161.)

“On such motions, a court may not go outside the pleadings, and all assumptions made and inferences drawn must favor the party against whom dismissal is sought.” (See id.)

“In reviewing cases involving the question of dismissal for failure to state a claim upon which relief can be granted, the only question before the appellate court is whether the complaint sets forth legally sufficient claims for relief.” (See id.)

General Information for Complaints and Motions

“[T]here is no justification for dismissing a complaint for insufficiency ... unless it appears to a certainty that the plaintiff would be entitled to no relief under any state of facts which could be proved in support of the claim.” (See Walsh v. U.S. Bank, N.A. (2014) 851 N.W.2d 598, 601-02.)

Standard of Review and Burdens of Proof

“In reviewing an order of dismissal under rule 12.02(e), the only question before this court is whether the complaint sets forth a legally sufficient claim for relief.” (See Larson v. Mitch's Inc., No. A07-0387, at *3 (Minn. Ct. App. July 1, 2008).)

“If no relief could be granted under any set of facts consistent with the allegations that could be proved, dismissal is appropriate.” (See id.)

“On appeal from a judgment of dismissal for failure to state a claim on which relief can be granted, we review de novo the legal sufficiency of the claim.” (See Watson's Properties, LLC v. Menard, Inc., No. C0-01-2085, at *1 (Minn. Ct. App. June 19, 2002).)

“In reviewing the legal sufficiency of a pleading, this court accepts all facts alleged in the complaint as true and makes all reasonable inferences in favor of the non-moving party.” (See Larson v. Mitch's Inc., No. A07-0387, at *3 (Minn. Ct. App. July 1, 2008).)

The Court’s Decisions

It is well settled that “dismissal of a complaint for failure to state a claim is proper if there are no facts consistent with the pleading that support the relief demanded.” (See Watson's Properties, LLC v. Menard, Inc., No. C0-01-2085, at *1 (Minn. Ct. App. June 19, 2002).)

It is also well settled that “the facts set forth in the complaint are accepted as true, and the plaintiff has the benefit of all favorable and reasonable inferences.” (See id.)