821 N.W.2d 576
Minn.2012Background
- Weavewood, Inc. owned property in Golden Valley and had a Mortgage granted in 1998 by its trustee for Williams; the Mortgage’s validity was later challenged.
- Weavewood knew of the Mortgage’s alleged defects by 2000 and pursued claims against Williams’s probate estate, then against Stevenson, later abandoning those claims.
- In 2009, the Mortgage was assigned to Palladium and then to S & P, which began foreclosure proceedings in 2009.
- Weavewood sought a declaratory judgment that the Mortgage was void or satisfied and moved for a TRO to enjoin the sheriff’s sale; the TRO was dissolved and the petition dismissed as time-barred by the district court.
- The court of appeals held some monetary claims were time-barred but suggested declaratory relief could avoid limitations; this Court granted review on whether statutes of limitations apply to declaratory judgment actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do statutes of limitations apply to declaratory judgment actions? | Weavewood argued DJ is a defense, not an affirmative claim (no limitations). | S & P urged that limitations apply to DJ the same as nondeclaratory claims. | Statutes of limitations apply to DJ to the same extent as nondeclaratory actions. |
| Is Weavewood's declaratory judgment action timely filed? | Weavewood contends the action is defensive and thus not time-barred. | S & P contends the action should be barred under applicable limitations. | Court remands to determine whether the complaint presents pure defenses or affirmative relief and timeliness. |
Key Cases Cited
- Int’l Ass’n of Machinists & Aerospace Workers v. Tenn. Valley Auth., 108 F.3d 658 (6th Cir. 1997) (statutes of limitations bar DJ to same extent as nondeclaratory action)
- Wilson v. Kelley, 224 Conn. 110 (1992) (DJ action must present cognizable underlying claim)
- Portlance v. Golden Valley State Bank, 405 N.W.2d 240 (Minn. 1987) (limitations depend on nature of the wrong, not relief sought)
- Bachertz v. Hayes-Lucas Lumber Co., 201 Minn. 171 (1937) (limitations commence when action can be commenced)
- State v. Joseph, 622 N.W.2d 358 (Minn. App. 2001) (overruled decision that DJ commencement is not subject to any statute of limitations)
- Gilbert v. City of Cambridge, 932 F.2d 51 (1st Cir. 1991) (supports same limitations rule for DJ)