Cited by

d 303, 309-10 (Minn. 2003) (stating that new-trial motion is not a prerequisite to appellate review of substantive legal issues properly raised and considered in district court); (stating that, absent motion for new trial, appellate courts may review whether evidence

Alpha Real Est. Co. of Rochester v. Delta Dental Plan of Minn.

d 303, 309-10 (Minn. 2003) (stating that new trial motion is not prerequisite to appellate review of substantive legal issues properly raised and considered in district court); (stating that absent motion for 5 new trial, appellate courts may review whether evidence

And a motion for a new trial is “not a prerequisite for appellate review of substantive questions of law when a genuine issue of law is properly raised and considered at the district court level.”

-10 (Minn. 2003) (stating that new- trial motion is not prerequisite to appellate review of substantive legal issues properly raised and considered in district court); d 565, 569 (Minn. 1976) (stating that absent motion for new trial, appellate courts may review whether evidence

ol evidence rule ‘prohibits the admission of extrinsic evidence of prior or contemporaneous oral agreements, or prior written agreements, to explain the meaning of a contract when the parties have reduced their agreement to an unambiguous integrated 13 writing.’” ().

(holding that the “district court erred when it found that the absence of language in the 1997 lease regarding the survival of the five percent additional rent after the closing of the option was a result of mutual mistake or scrivener’s error”).

Alpha Real Est. Co. of Rochester v. Delta Dental Plan of Minn ., -311 (Minn. 2003) .

A posttrial motion “gives the [district] court time to consider the context of the objection and the effect the error may have had on the outcome of the case.”

If “the parties did not intend the agreement to be a complete integration, then parol evidence can be used to prove the existence of a separate consistent oral agreement.”

A posttrial motion “gives the court time to consider the context of the objection and the effect the error may have had on the outcome of the case.”

That is so because a motion for new trial may “eliminate the need for appellate review,” “facilitate development of ‘critical aspects of the record ,’” and “provide the district court with the opportunity to correct its own errors.” (quoting Sauter, d at 201).

The purpose of this requirement is two-fold: (1) to “eliminate the need for appellate review;” and (2) “if appellate review is sought,” to “facilitate development of critical aspects of the record.” Alpha Real Est. Co. v. Delta Dental P lan, (quotation omitted).

Such a motion serves to either “eliminate the need for appellate review” or, “if appellate review is sought,” to “facilitate development of ‘critical aspects of the record.’” 4 (Minn. 2003) (discussing motion for new trial) (d 200, 201 (Minn. 1986)).

ies have reduced their agreement to an unambiguous integrated writing,” courts cannot interpret that written agreement by relying on extrinsic evidence, including “extrinsic evidence of prior or contemporaneous oral agreements, or prior written agreements.” ( ).

“The parol evidence rule prohibits the admission of extrinsic evidence of prior or contemporaneous oral agreements, or prior written agreements, to explain the meaning of a contract when the parties have reduced their agreement to an unambiguous integrated writ ing.” Alpha Real Est. Co. of Rochester v. Delta Dental Plan of Minn ., (quotation omitted).

–10 (Minn. 2003) (stating that new-trial motion is not prerequisite to appellate review of substantive legal issues properly raised and considered in district court); Gruenhagen v. Larson , (stating that absent motion for new trial, appellate courts may review whether evidence

–10 (Minn. 2003) (stating that new-trial motion is not prerequisite to appellate review of substantive legal issues properly raised and considered in district court); Gruenhagen v. Larson, 310 Minn. 454, 458, (stating that absent motion for new trial, appellate courts may review wheth

1 See Alpha Real Estate Co. of Rochester v. Delta Dental Plan of Minn. , (holding that in absence of a motion for a ne w trial, our scope of review is limited to substantive legal issues properly raised to and considered by the district court).

We will also review substantive questions of law that were “properly raised and considered at the district court level.”

“Matters of trial procedure, evidentiary rulings, and jury instructions occurring at trial are subject to appellate review only if they are assign ed as error in a motion for a new trial.” County of Hennepin v. Bhakta , 9 see also Alpha Real Estate Co. of Rochester v. Delta Dental Plan of Minn ., (clarifying that only substantive questions of law properly raised and considered by district court are subject to appellate review without making a motion for new trial); (same).

(clarifying only substantive questions of law properly raised and considered by the district court may receive appellate review without making a motion for new trial).

We also may review any “substantive questions of law when a genuine issue of law is properly raised and considered at the district court level.”

But, a motion for a new trial is “not a prerequisite for appellate review of substantive questions of law when a genuine issue of law is properly raised and considered at the district court level.”

-09, 311 (Minn. 2003); Gruenhagen v. Larson

When there is an unambiguous integrated written contract, “[t]he parol evidence rule prohibits the admission of extrinsic evidence of prior or contemporaneous oral agreements, or prior written agreements, to explain the meaning of a contract.” Alpha Real Estate Co. of Rochester v. Delta Dental Plan of Minn ., (quotation omitted) .

see also Alpha Real Estate Co. of Rochester v. Delta Dental Plan of Minn. , (allowin g appellate review of the parol -evidence rule despite failure to file a posttrial motion for a new trial, when the issue was “properly raised and considered at the district court level”) .

at 911 (quoting Alpha Real Estate Co. of Rochester v. Delta Dental Plan of Minn. , , 311 (Minn. 2003) ).

City of Minneapolis v. Minneapolis Police Relief Ass'n , , 172 (Minn. App. 2011) (citing Alpha Real Estate Co. of Rochester v. Delta Dental Plan of Minn. , , 309-10 (Minn. 2003) ; Gruenhagen v. Larson , 310 Minn. 454 , , 569 (1976) ).

When there is an unambig uous integrated written contra ct, “[t]he parol evidence rule prohibits the admission of extrinsic evidence of prio r or contemporaneous oral agreements, or prior written agreements, to explain the meaning of a contract.”

P. 59.01 are not a prerequisite for appellate review of substantive questions of law when a genuine issue of law is properly raised and considered at the district court level.”

of Hennepin, (quoting Alpha Real Estate , -11 (Min n. 2003)).