Minch Family LLLP v. Buffalo-Red River Watershed District
628 F.3d 960
| 8th Cir. | 2010Background
- BRRWD obtained a Minnesota court order to clean out a ditch on Minch land with limitations on scope.
- BRRWD performed the clean-out; workers entered Minch land and left equipment/ spoils on site.
- Minch sued in federal court under 28 U.S.C. § 1332 claiming trespass, nuisance, and wrongful death.
- District court granted judgment on the pleadings, citing Rooker-Feldman, res judicata, collateral estoppel, and pleading deficiencies.
- Minnesota state court had previously determined BRRWD could act to clean the ditch but not necessarily beyond its scope; appeal addressed interpretation of that order.
- Minch died during litigation; case proceeded as to his estate and successors in interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rooker-Feldman applicability | Minch seeks relief from acts, not reversal of state ruling. | District court correctly applied Rooker-Feldman to bar claims based on state judgment. | Rooker-Feldman does not apply. |
| Collateral estoppel | State-court findings preclude relitigation of issues. | Issue not identical to prior adjudication; estoppel not applicable. | Collateral estoppel does not apply. |
| Res judicata | Earlier action forecloses later trespass/nuisance claims. | Different time and scope; not the same cause of action. | Res judicata does not apply. |
| Trespass sufficiency | Entry onto Minch land was unlawful beyond the order. | Order authorized access; no unlawful entry. | Trespass claim dismissed; entry authorized by order in context. |
| Nuisance and wrongful death sufficiency | Deterioration and disruption on land constitute nuisance; death claim should lie. | No interference with use beyond authorized activity; no wrongful death liability. | Nuisance and wrongful death claims dismissed. |
Key Cases Cited
- Rooker v. Fid. Trust Co., 263 U.S. 413 (1923) (established original jurisdiction limits in state-judgment challenges)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (narrow scope of Rooker-Feldman for illegal acts by parties)
- Riehm v. Engelking, 538 F.3d 952 (8th Cir.2008) (Rooker-Feldman governs challenges to state judgments vs. illegal acts by adversaries)
- Hauschildt v. Beckingham, 686 N.W.2d 829 (Minn.2004) (collateral estoppel elements; mixed questions of law and fact)
- Kaiser v. N. States Power Co., 353 N.W.2d 899 (Minn.1984) (foundational understanding of res judicata elements)
- Laska v. Anoka Cnty., 696 N.W.2d 133 (Minn.Ct.App.2005) (Minnesota wrongful death elements and duty concepts)
- Wendinger v. Forst Farms, Inc., 662 N.W.2d 546 (Minn.Ct.App.2003) (trespass versus nuisance distinction in Minnesota)
- McMenomy v. Ryden, 276 Minn. 55, 148 N.W.2d 804 (Minn.1967) (test for whether two claims share the same cause of action)