Under Minn. Stat. § 504B.321, the complaint in an Eviction Action must “describe[] the premises of which possession is claimed”. There is only one Minnesota appellate case — Lewis v. Steele, decided by the Territorial court — stating what the description must entail. As discussed in this essay (in PDF and Word versions), the description must be definitive on the face of the complaint. Two Hennepin County trial court decisions are in accord, enforcing this rule as well as a Housing-Court rule requiring a correct street address.
This essay reviews the legislative history of Minn. Stat. § 504B.321 and its predecessor statutes. It discusses the history and functioning of the Territorial courts, and whether Territorial court decisions are binding precedent on Minnesota State courts. I conclude that such decisions are not binding but that the legislative history of Minn. Stat. § 504B.321, a Wisconsin case like Lewis v. Steele, and the rules of statutory construction together make Lewis v. Steele good law.
The Word version of the essay has links to cited materials, including some interesting (at least to me) materials about the Minnesota Territory and its courts.
I thank Lee Bennin for helpful hints about how to decide if Territorial cases are binding precedent.
Birnberg Minnesota Legislative Newsletter 