American Sharecom, Inc. v. LDB Intern. Corp., No. CX-96-411
| Court | Court of Appeals of Minnesota |
| Writing for the Court | HARVEY A. HOLTAN |
| Citation | 553 N.W.2d 433 |
| Docket Number | No. CX-96-411 |
| Decision Date | 13 August 1996 |
| Parties | AMERICAN SHARECOM, INC., Appellant, v. LDB INTERNATIONAL CORPORATION, et al., Respondents. |
Page 433
v.
LDB INTERNATIONAL CORPORATION, et al., Respondents.
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.
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.
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.
Does the district court have subject matter jurisdiction to reopen a satisfied judgment when a party alleges that the judgment was fraudulently obtained?
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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Hanson v. Woolston, No. A04-1628.
...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......
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Smith v. Price Development Co., No. 20040675.
...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......
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Popp Telecom, Inc. v. American Sharecom, No. 03-2124.
...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......
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Telcom v. American Sharecom, Inc., PLAINTIFFS-APPELLANTS
...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 ......
-
Hanson v. Woolston, No. A04-1628.
...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.
...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.
...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
...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 ......