In a ruling this week, the Minnesota Supreme Court rejected the stricter pleading standard adopted by the United States Supreme Court. This means that lawsuits will be more difficult to dismiss-- at least through an early motion to dismiss from defendants. The Court's holding is below:
we now decline to engraft the plausibility standard from Twombly and Iqbal onto our traditional interpretation of Minn. R. Civ. P. 8.01. We decline to do so despite the fact that the relevant text of Fed. R. Civ. P. 8(a)(2) is identical to the text of Minn. R. Civ. P. 8.01. The similarities between the federal rule and our rule make Twombly and Iqbal “instructive,” but not binding. See T.A. Schifsky & Sons, Inc. v. Bahr Constr., LLC, 773 N.W.2d 783, 787 n.3 (Minn. 2009) (“Where the language of the Federal Rules of Civil Procedure is similar to language in the Minnesota civil procedure rules, federal cases on the issue are instructive.”). We are not bound because we have the power to “regulate the pleadings, practice, procedure, and the forms thereof in civil actions in all courts of this state.” Minn. Stat. § 480.051 (2012). In our view, the plain language of Rule 8.01, its purpose and history, and its procedural context make clear that the rule means today what it meant at the time Olson and Franklin were decided. A claim is sufficient against a motion to dismiss for failure to state a claim if it is possible on any evidence which might be produced, consistent with the pleader’s theory, to grant the relief demanded.
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