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Keywords

contractlawsuitbreach of contractjurisdictionappealpleamotionwillappellantwrit of certiorarimotion to dismiss
jurisdictionappealpleamotionrespondentappellantmotion to dismiss

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Williams v. Board of Regents of University of Minnesota, 763 N.W.2d 646, 243 Ed. Law Rep. 858

Facts

James Williams, an alleged employee of the University of Minnesota, filed a lawsuit against the university and its athletic director, Joel Maturi, claiming breach of contract and other related claims. Williams asserted that he was verbally offered a position as an assistant coach by the head coach, Orlando Smith, and relied on this offer to resign from his previous job at Oklahoma State University. After the alleged offer, Maturi publicly denied that Williams had been hired, leading to the lawsuit. The district court granted a motion to dismiss, prompting Williams to appeal.

Issue

Did the district court err in ruling that it did not have subject-matter jurisdiction over appellant's common-law claims for promissory estoppel, equitable estoppel, and negligent misrepresentation?

Did the district court err in ruling that it did not have subject-matter jurisdiction over appellant's common-law claims for promissory estoppel, equitable estoppel, and negligent misrepresentation?

Rule

The district court must take the facts alleged in the complaint as true and draw all inferences in favor of the nonmoving party when deciding a motion for judgment on the pleadings. The appellate court reviews the judgment on the pleadings de novo, determining whether the complaint sets forth a legally sufficient claim for relief. Subject-matter jurisdiction over claims against public employers is limited to situations where the claims do not implicate the executive body's decision to terminate an employee, which can only be reviewed through a writ of certiorari.

In deciding a motion for judgment on the pleadings, the district court must take the facts alleged in the complaint as true and draw all inferences in favor of the nonmoving party. 48 M.S.A., Rules Civ.Proc., Rule 12.03.

Analysis

The court analyzed whether the claims of promissory and equitable estoppel required examination of the university's internal hiring procedures and the ultimate decision not to employ Williams. Since these claims were intertwined with the university's employment decisions, the district court correctly determined it lacked jurisdiction. However, the negligent misrepresentation claim did not challenge the hiring decision directly and could be evaluated without delving into the university's discretionary decisions, thus the district court erred in dismissing it.

The district court concluded that because the university's employment decisions are subject only to certiorari review in the court of appeals, the district court did not have jurisdiction to hear the common-law counts and granted respondents' motion to dismiss based on the pleadings.

Conclusion

The court affirmed the district court's dismissal of the estoppel claims for lack of jurisdiction but reversed the dismissal of the negligent misrepresentation claim, remanding it for further proceedings.

We conclude that the district court correctly determined that judicial consideration of appellant's estoppel counts are limited to a certiorari appeal to the court of appeals and that appellant's constitutional counts failed to present a claim for which relief could be granted, but erred in determining that it did not have jurisdiction over appellant's negligent-misrepresentation claim.

Who won?

The University of Minnesota and Joel Maturi prevailed in part because the court upheld the dismissal of the promissory and equitable estoppel claims, determining that these claims were subject to certiorari review only. The court found that the district court correctly ruled it lacked jurisdiction over these claims, which were closely tied to the university's employment decisions.

The University of Minnesota and its athletic director, Joel Maturi, prevailed in part because the court upheld the dismissal of the promissory and equitable estoppel claims, determining that these claims were subject to certiorari review only, thus affirming the district court's ruling on those counts.

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