Cited by

In the context of sanctions for spoliation, the Minnesota Supreme Court has stated that the party challenging the district court’s choice of sanction bears the burden to show that “it is clear that no reasonable person would agree with the [district] court’s assessment of what sanctions are appropriate.” (quotation omitted).

impose sanctions as necessary to protect their “vital function—the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.” (quotation omitted); -19 (Minn. 1995) (discussing a district court’s “considerable” inherent authority to sanction a party for destroying evidence).

as authority for the sanctions imposed.

In Minnesota, “courts are vested with considerable inherent judicial authority.”

District courts possess inherent authority to impose sanctions as necessary to protect their “vital function—the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.” 12 (Minn. 1995) (quotations omitted).

District courts are “vested with considerable inherent judicial authority necessary to their vital function—the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.” -19 (Minn. 1995) (quotation omitted).

P. 37.02(b)(3) (providing that a court may dismiss a party’s action or render a default judgment for disobeying discovery orders); -19 (Minn. 1995) (stating that district court judges have “inherent judicial authority” to address party misconduct).

ssess inhe rent authority to impose sanctions as necessary to protect their ‘vital function—the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.’” Peterson v. 2004 Ford Crown Victoria, ().

Patton v. Newmar Corp ., (Mi nn.

(holding district court “has the inherent power to impose sanctions” for evidence spoliation and in doing so must determine “the impact of the spoliation—the prejudice to the opposing party”).

See Patton v. Newmar Corp. , d 116, 120 (Minn. 1995) (determining “bare conclusions” supported by “few facts beyond those which could be expected to be contained in the complaint” insufficient to withstand summary judgment).

11 without delay, conformable to the laws.” (quotation omitted).

The party challenging a district court’s choice of sanction “has the difficult burden of convincing an ap pellate court that the [district] court abused its discretion —a burden which is met only when it is clear that no reasonable person would agree [with] the [district] court’s assessment of what sanctions are appropriate.” (quotation omitted); accord In re Kujawa , 270 F.3d 578, 582 (8th Cir. 2001) (stating that appellate courts review sanctions imposed pursuant to a court’s inherent authorit

(holding that a court must consider whether evidence was critical to a claim and the extent of prejudice to the opposing party in deciding whether to impose spoliation sanctions).

Patton v. Newma r Corp .

See Patton v, Newman Corp., (stating that a district court’s inherent authority permits it to deliver “remedies for wrongs”).

1 We review a district court’s imposition of a sanction for an abuse of discretion, which is only met “when it is clear that no reasonable person would agree with the trial court’s assessment of what sanctions are appropriate.” Patton v. Newmar Corp. , (quotation omitted).

“One challenging the trial court’s choice of a sanction has the difficult burden of convincing an appellate court that the trial court abused its discretion—a burden which is met only when it is clear that no reasonable person would agree with the trial court’s assessment of what sanctions are appropriate.” (quotation omitted).

“The task of determining what, if any, sanction is to be imposed is implicated by the broad authority provided the trial court.”

The task of determining what, if any, sanction is to be imposed is implicated by the broad authority provided the trial court.” -19 (Minn. 1995) (citations and quotations omitted).

The Knazzes next challenge the district court’s award of attorney fees to Christensen, which it issued under its “inherent power.” District courts “are vested with considerable inherent judicial authority necessary to their vital function.” (quotation omitted).

DECISION The district courts have authority to impose sanctions as necessary to protect their “vital function—the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.” (quotation omitted).

Kelleys’ counsel “performed with professionalism, integrity, courtesy, and candor throughout these proceedings” and that “[t]his included their change of law firms which brought about a Motion to Disqualify.” Whether a party acts in good faith is a credibility question, and we defer to the district 1 For the first time in his reply brief, the district court should have used its “inherent authority” to award attorney fees for the discovery violations.

addition to the statutory and rule-based authority to impose sanctions, district courts possess inherent authority to impose sanctions as necessary to protect their “vital function — the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.” (quotations omitted) (excluding expert witness testimony for spoliation of evidence).

“On review, an appellate court considers whether the district court is authorized to impose a sanction for spoliation of evidence and, if so, whether it abused its discretion by imposing such a sanction.” (), review denied (Minn. Nov.

ked inherent authority “to shift attorneys’ fees and award delay damages.” But “courts are vested with considerable inherent judicial authority necessary to their ‘vital function — the disposition of individual cases to deliver remedies for wrongs and justice freely and without purchase; completely and without denial; promptly and without delay, conformable to the laws.’ ” (Patton II).

investigation, Supreme Pork significantly altered the scene from its post-fire condition by removing and/or destroying relevant evidence,” and that in Minnesota, “the district court judge likely would have excluded Supreme Pork’s expert’s opinion, resulting in a dismissal of the entire case for spoliation, [regardless of] the plaintiffs specific intent or bad faith.” (affirming the district court’s exercise of *34 discretion to exclude plaintiffs expert’s report, where an allegedly defective mot