Cited by

4 4 The supreme court states that a deferential standard of review, not de novo, may still be appropriate on summary judgment after a district court “balances the equities” and “determines not to award equitable relief.” SCI Minn. Funeral Servs.

In addition, the formation of a contract “requires mutual assent among the parties involved in the transaction.” SCI Minn. Funeral Serv s., Inc. v. Washburn -McReavy Funeral Corp.

SCI Minn. Funeral Servs.

SCI Minn. 7 Funeral Servs., –61 (Minn. 2011).

“Reformation is an equitable remedy that is available when a party seeks to alter or amend language in a [deed] so that the [deed] reflects the parties’ true intent when they entered into the contract.” SCI Minn. Funeral Servs.

“Rescission is an equitable remedy,” SCI Minn. Funeral Servs., “which not only terminates the contract but abrogates it and undoes it from the beginning,” Johnny’s

7 B. Mutual Assent To form a mediated settlement agreement, mutual assent must exist, which “entails a meeting of the minds concerning a contract’s essential elements.” SCI Minn. Funeral Servs., (quotation omitted).

“Rescission is an equitable remedy.” SCI Minn. Funeral Servs., .

14 But even if there were such a scrivener’s error, a party seeking reformation of a contract based on mutual mistake must prove, among other things, that “there was a valid agreement sufficiently expressing in terms the real intention of the parties.” SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp., aff’d

n.4 (Minn. 2023); SCI Minn. Funeral Servs., -61 (Minn. 2011).

See, e.g., SCI Minn. Funeral Servs., (contracting to sell stock in a cemetery association); Nichols v. Shelard Nat’l Bank, (contracting for a mortgage on a home); (contracting to retain an attorney); S. Minn. Mun.

The formation of a contract “requires mutual assent among the parties involved in the transaction.” SCI Minn. Funeral Servs.

3 See SCI Minn. Funeral Servs., Inc. v. Washburn - McReavy Funeral Corp., (reviewing cross-motions for summary judgment de novo when the motions were based on undisputed facts).

See, rev. denied (Minn. May 21, 2013); see also SCI Minn. Funeral Servs., (noting that “[a] deferential standard of review might be applicable where, after balancing the equities, the district court 10 I. We first address Weeres’s argument that the ALJ erred by assigning to him the burden of proving that he has a duty disability.

See SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp. , –61 (Minn. 2011).

failed to receive evidence regarding the equitable relief sought.” “[R]eformation of a written agreement is available when parties reached an agreement, attempted to reduce it to writing, but failed to express [the agreement] correctly in the writing.” SCI Minn. Funeral Servs., aff’d

SCI Minn. Funeral Servs., ().

SCI Minn. Funeral Servs., Inc. v. Washburn- McReavy Funeral Corp ., .

See SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp. , (stating that legal decisions on cross-motions for summary judgment based on undisputed facts are reviewed de novo even if the matters decided “are for equitable rel ief”); St.

Contract reformation “is an equitable remedy that is available when a party seeks to alter or amend language in a contract so that the contract reflects the parties’ true intent when they entered into the contract.” SCI Minn. Funeral Servs., Inc. v. Washburn- McReavy Funeral Corp .

v. Washburn-McReavy Funeral Corp., (quotation omitted).

Brown v. Lee, 859 -40 (Minn. App. 2015), rev. denied (Minn. May 19, 2015) (concluding that “a more deferential standard of review” was inapplicable because the district court, “without balancing the equities,” concluded that a claim failed “as a matter of law”); see also SCI Minn. Fune ral Servs., d 855, 861 (Minn. 2011) (“We review legal decisions on summary judgment under a de novo standard.

The parties to a contract must have a “meeting of the minds concerning a contr act’s essential elements.” SCI Minn. Funeral Servs., (quotation omitted).

“When the relevant facts are undisputed, the existence of mutual assent is a legal question that we review de novo.” SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy 6 Funeral Corp., aff’d

SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp.

“Minnesota follows the objective theory of contract formation, under which an outward manifestation of assent is determinative, rather than a party’s subjective intention.” Speckel by Speckel v. Perkins , see also SCI Minn. Funeral Servs., (“Whether mutual assent exists is tested under an objective standard.”).

Reformation of Deed “[R]eformation of a written agreement is available when parties reached an agreement, attempted to reduce it to writing, but failed to express [the agreement] correctly in the writing.” SCI Minn. Funeral Servs., , aff’d, .

“Reformation is an equitable remedy that is available when a party seeks to alter or amend language in a contract so that the contract reflects the parties’ true intent when they entered into the contract.” SCI Minn. Funeral Servs.

And “[r]eformation is an equitable remedy that is available when a party seeks to alter or amend language in a contract so that the contract reflects the parties’ true intent when they entered into the contract.” SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp.

SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp. , -61 (Minn. 2011) (T he “standard of review does n ot change simply because the claims at issue are for equitable relief.”).

Mutual assent requires a “meeting of 5 the minds concerning [a contract’s] essential elements.” SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp. , (quotation omitted).

Contract reformation Contract reformation “is an equitable reme dy that is available when a party seeks to alter or amend language in a contract so that th e contract reflects the parties’ true intent when they entered into the contract.” SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp.

“Reformation is an equitable remedy that is available when a party seeks to alter or amend language in a contract so that the contract reflects the parties’ true intent when they entered into the contract.” SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp.

SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp. , 866 (Minn. 2011).

reason for affirmance” on appeal even if not the one relied on by the district court); see also SCI Minn. Funeral Servs., 14 Inc. v. Washburn -McReavy Funeral Corp. , (stating that this court may consider issues that were presented to but not decided by the district court when the facts are undisputed and both parties have briefed the issue), aff’d

SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp.

See, e.g. , SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp. , (stating that appellate courts review the district court’s legal determinations de novo).

The offer and acceptance requirements of contract formation are satisfied if there is a “meeting of the minds concerning a contract’s essential elements.” SCI Minn. Funeral Servs., Inc. v. Was hburn-McReavy Funeral Corp.

SCI Minn. Funeral Servs.

“Reformation is an equitable remedy that is available when a party seeks to alter or amend language in a contract so that the contract reflects the parties’ true intent when they 4 entered into the contract.” SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp.

SCI Minn. Funeral Servs., Inc. v. Washburn -McReavy Funeral Corp., aff’d

See SCI Minnesota Funeral Servs.

SCI Minn. Funeral Servs., (quotation omitted), aff’d