Park Nicollet Clinic v. Hamann
808 N.W.2d 828
| Minn. | 2011Background
- Hamann employed by Park Nicollet Clinic since 1974 in OB/GYN; 1995 policy provided night-call relief for eligible physicians; April 2005 Park Nicollet refused to honor policy after eligibility; Hamann alleged breach of contract and promissory estoppel; February 2008 salary reduction followed by Hamann filing suit in October 2009; Court holds accrual in April 2005 and statute of limitations bars claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did the claim accrue for statute of limitations purposes? | Hamann argues accrual later. | Park Nicollet argues accrual in April 2005. | accrual in April 2005; timely only if suit filed within 2 years. |
| Do continuing pay-period breaches create new causes of action? | Hamann contends each noncompliant pay period accrues anew. | Park Nicollet contends no continuing obligation after April 2005. | No; April 2005 breach was a single event giving rise to the action. |
| Is the April 2005 repudiation an anticipatory repudiation that delays accrual? | Leads to continued accrual from future obligations. | Statements did not anticipatorily repudiate future obligations. | Not anticipatory repudiation; breach occurred in April 2005. |
Key Cases Cited
- Bachertz v. Hayes-Lucas Lumber Co., 201 Minn. 171 (Minn. 1937) (statute accrues when breach occurs; limitations start then)
- Dalton v. Dow Chem. Co., 280 Minn. 147 (Minn. 1968) (accrual when all elements present; damages need not be known)
- Levin v. C.O.M.B. Co., 441 N.W.2d 801 (Minn. 1989) (annual commissions; discrete accrual dates; not controlling here)
- Levin v. C.O.M.B. Co., 441 N.W.2d 801 (Minn. 1989) (distinguishes ongoing wage obligations from present breaches)
- Olson v. Synergistic Techs. Bus. Sys., Inc., 628 N.W.2d 142 (Minn. 2001) (promissory estoppel elements applied)