American Sharecom, Inc. v. LDB Intern. Corp., No. CX-96-411

CourtCourt of Appeals of Minnesota
Writing for the CourtHARVEY A. HOLTAN
Citation553 N.W.2d 433
Docket NumberNo. CX-96-411
Decision Date13 August 1996
PartiesAMERICAN SHARECOM, INC., Appellant, v. LDB INTERNATIONAL CORPORATION, et al., Respondents.

Page 433

553 N.W.2d 433
AMERICAN SHARECOM, INC., Appellant,
v.
LDB INTERNATIONAL CORPORATION, et al., Respondents.
No. CX-96-411.
Court of Appeals of Minnesota.
Aug. 13, 1996.

Syllabus by the Court

1. A district court lacks jurisdiction to vacate a satisfied judgment, even if the judgment was fraudulently obtained.

2. Minn. R. Civ. P. 60.02 only applies to judgments before they are satisfied.

Robert J. Hennessey, Wallace G. Hilke, Charles J. Lloyd, Lindquist & Vennum, P.L.L.P., Minneapolis, for Appellant.

Thomas S. Fraser, James E. Dorsey, III, Crystal Olsen Glynn, Fredrickson & Byron, Minneapolis, for Respondents.

Considered and decided by WILLIS, P.J., and DAVIES and HOLTAN, JJ.

OPINION

HARVEY A. HOLTAN, Judge *.

After a judgment was paid and a notice of satisfaction filed, one party made a motion to set aside the judgment under Minn. R. Civ. P. 60.02, claiming the judgment was procured by fraud. The opposing party claims the district court has no jurisdiction to set aside a satisfied judgment. Without addressing the jurisdictional issue, the district court essentially denied that motion by setting a hearing on the merits. We reverse.

FACTS

This action arose from a squeeze-out merger involving appellant American Sharecom, Inc. (ASI), a reseller of long distance telephone service. Respondents, as minority shareholders, dissented from the merger and initiated a valuation proceeding. ASI was valued at more than $25.6 million, and respondents were awarded approximately $5 million for their share of the corporation. After affirmance by this court, 1 ASI paid the

Page 434

judgment in full, and a notice of satisfaction was filed.

Several months later, respondents made a motion under rules 59 and 60 to set aside the judgment based on fraud and newly discovered evidence. They allege that during discovery, trial, and posttrial motions, ASI concealed evidence relevant to the value of the corporation. ASI moved to strike respondents' motion, arguing that the district court did not have subject matter jurisdiction to reopen a satisfied judgment. The district court denied ASI's motion and set the matter for a hearing on the merits.

ISSUE

Does the district court have subject matter jurisdiction to reopen a satisfied judgment when a party alleges that the judgment was fraudulently obtained?

ANALYSIS

Orders granting or denying motions based on subject matter jurisdiction are appealable as of right. Judd v. State by Humphrey, 488 N.W.2d 507, 508 (Minn.App.1992). Whether a court has jurisdiction is a question of law reviewed de novo. Graham v. Crow Wing County Bd. of Comm'rs, 515 N.W.2d 81, 84 (Minn.App.1994), review denied (Minn. June 2, 1994).

Respondents made a motion to vacate the judgment, claiming ASI intentionally misled the court about the value of the corporation. A district court may set aside a final judgment if the judgment was obtained by fraud. Minn. R. Civ. P. 60.02(c). The rule does not state whether it applies to satisfied judgments. 2

Minnesota courts have held that a satisfied judgment cannot be vacated. Dorso Trailer Sales, Inc. v. American Body & Trailer, Inc., 482 N.W.2d 771, 773 (Minn.1992);...

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5 practice notes
  • Hanson v. Woolston, No. A04-1628.
    • United States
    • Court of Appeals of Minnesota
    • 26 Julio 2005
    ...judgment. Dorso Trailer Sales, Inc. v. Am. Body & Trailer, Inc., 482 N.W.2d 771, 773 (Minn.1992); Am. Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433, 435 (Minn.App.1996) (stating that district court lacks subject-matter jurisdiction to set aside satisfied judgment, even if judgment fraud......
  • Smith v. Price Development Co., No. 20040675.
    • United States
    • Utah Supreme Court
    • 2 Diciembre 2005
    ...whatsoever in the underlying judgment. Once a judgment is paid, it is, by definition, satisfied. Am. Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433, 434 (Minn.Ct.App.1996) ("Once a judgment is satisfied, it ceases to exist. . . ."). The State's only interest, therefore, is one to the pro......
  • Popp Telecom, Inc. v. American Sharecom, No. 03-2124.
    • United States
    • United States Courts of Appeals. United States Court of Appeals (8th Circuit)
    • 27 Febrero 2004
    ...of Appeals ruled that the state district court lacked jurisdiction to vacate the judgment. See Am. Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433, 435 (Minn.Ct.App. 1996) ("Sharecom II"). The court noted that the Dissenters had another available remedy in the form of a separate common la......
  • Telcom v. American Sharecom, Inc., PLAINTIFFS-APPELLANTS
    • United States
    • United States Courts of Appeals. United States Court of Appeals (8th Circuit)
    • 19 Noviembre 1999
    ...the proceeding itself. However, six months later, the Minnesota Court of Appeals held in American Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433 Page 933 (Minn. Ct. App. 1996) (Sharecom II), that Judge Howard had no jurisdiction to vacate the satisfied judgment on the basis of fraud and ......
  • Request a trial to view additional results
5 cases
  • Hanson v. Woolston, No. A04-1628.
    • United States
    • Court of Appeals of Minnesota
    • 26 Julio 2005
    ...judgment. Dorso Trailer Sales, Inc. v. Am. Body & Trailer, Inc., 482 N.W.2d 771, 773 (Minn.1992); Am. Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433, 435 (Minn.App.1996) (stating that district court lacks subject-matter jurisdiction to set aside satisfied judgment, even if judgment fraud......
  • Smith v. Price Development Co., No. 20040675.
    • United States
    • Utah Supreme Court
    • 2 Diciembre 2005
    ...whatsoever in the underlying judgment. Once a judgment is paid, it is, by definition, satisfied. Am. Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433, 434 (Minn.Ct.App.1996) ("Once a judgment is satisfied, it ceases to exist. . . ."). The State's only interest, therefore, is one to the pro......
  • Popp Telecom, Inc. v. American Sharecom, No. 03-2124.
    • United States
    • United States Courts of Appeals. United States Court of Appeals (8th Circuit)
    • 27 Febrero 2004
    ...of Appeals ruled that the state district court lacked jurisdiction to vacate the judgment. See Am. Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433, 435 (Minn.Ct.App. 1996) ("Sharecom II"). The court noted that the Dissenters had another available remedy in the form of a separate common la......
  • Telcom v. American Sharecom, Inc., PLAINTIFFS-APPELLANTS
    • United States
    • United States Courts of Appeals. United States Court of Appeals (8th Circuit)
    • 19 Noviembre 1999
    ...the proceeding itself. However, six months later, the Minnesota Court of Appeals held in American Sharecom, Inc. v. LDB Int'l Corp., 553 N.W.2d 433 Page 933 (Minn. Ct. App. 1996) (Sharecom II), that Judge Howard had no jurisdiction to vacate the satisfied judgment on the basis of fraud and ......
  • Request a trial to view additional results

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