Ouradnik v. Ouradnik, 912 N.W.2d 674

Father owns 40 acres and allows only his immediate family to hunt; he excludes extended family, friends, and the public and posted at least one "No Trespassing" sign.
Father built multiple deer (tree) stands on the property; some boards were affixed with nails, others with screws.
Son climbed a deer stand, grabbed a board secured by nails, the board came loose, and Son fell ~16 feet, suffering serious injuries.
Son sued Father for personal injuries; Father moved for summary judgment claiming recreational-use immunity under Minn. Stat. §§ 604A.20-.27.
District court granted partial summary judgment applying Minn. Stat. § 604A.22 but allowed Son to proceed under the trespasser exception; a jury later found Son 95% negligent and the district court entered judgment for Father.
Court of appeals reversed, holding the Recreational-Use Statute requires the land be offered to the public; the Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether recreational-use immunity applies when land is not offered to the public	Ouradnik: statute requires land be offered for public use before immunity applies	Ouradnik (Father): immunity applies if §604A.22's three elements (permission, recreational purpose, without charge) are met regardless of public offer	Court: Immunity does not apply unless land is offered for public use; Hughes controls
Whether "the public" can be satisfied by exclusive use by immediate family	Ouradnik: "public" requires broader community use, not only family	Father: allowing immediate family should qualify as permission for recreational use	Court: "The public" unambiguously means more than immediate family; family-only use does not satisfy statute
Whether Hughes precedent still applies after statutory recodification	Ouradnik: recodification did not change meaning; Hughes remains binding	Father: implied argument that §604A.22 standing alone governs immunity	Court: Hughes remains binding because the statutory language including "by the public" is essentially unchanged
Standard of review for statutory interpretation	Ouradnik: statutory interpretation reviewed de novo	Father: same	Court: review de novo (cites Cocchiarella)

Hughes v. Quarve & Anderson Co., 338 N.W.2d 422 (Minn. 1983) (Recreational-Use Statute inapplicable where landowner discouraged public use)
Cocchiarella v. Driggs, 884 N.W.2d 621 (Minn. 2016) (statutory-interpretation questions reviewed de novo)
Engquist v. Loyas, 803 N.W.2d 400 (Minn. 2011) (prior judicial construction of statutory language guides subsequent interpretation)