MN Court of Appeals Clarifies Paternity Rules

Minnesota case law summary by Attorney Richard Clem: parentage.

Ramsey County, et al., v. X.L., et al.. MN parentage

This case was a consolidated appeal of a number of parentage actions from Ramsey County. In each of them, the parents were minors and signed, while they were still minors, "recognition of parentage" documents for the child.

In each case, the child was receiving public assistance, and Ramsey County brought these parentage actions.

Because these documents had been signed and the fathers were listed on the birth certificates, the district court refused to adjudicate paternity, and dismissed that portion of the action. The County appealed. The Minnesota Court of Appeals held:

Minnesota Statutes section 257.75 did not bar the county from filing a parentage action to adjudicate the father-child relationship, even though a minor parent has signed the "recognition of parentage" and no competing presumptions of paternity existed.

Nos. A14-0346 and A14-0347 (Minn. Ct. App. Sept. 2, 2014).

Please see the original opinion for the court's exact language.


Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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