Seven Acquisition LLC v. Gregg Williams

Summary

The Minnesota Supreme Court held that quasi-judicial immunity bars a commercial tenant's breach-of-fiduciary-duty claim against a court-appointed receiver where every alleged act—declining repairs, pursuing rent, taking direction from the mortgagee, and allegedly conspiring with the mortgagee—fell within the scope of the receivership. Allegations of improper motive or of a conspiracy with a party cannot defeat the immunity, and a bare legal conclusion that the receiver acted outside the scope will not survive a motion to dismiss under Minnesota's notice-pleading standard. The court affirmed the court of appeals' reversal of the district court's refusal to dismiss. No separate opinions were filed.