Probate & Trust Law Section Conference Manual ... - Minnesota CLE

amendment to Minn. Stat. § 519.05(a) effective July 1, 2009 provided the basis to
recover the claim. The Court ruled that the County’s claim under spousal liability is
barred by the doctrine of collateral estoppel. Even if collateral estoppel did not apply,
the Court held that the 2009 amendments to Minn. Stat. § 519.05 could not apply
because the marriage between Donald and Janis ended at Janis’ death in 2008 and the
amendment became effective in 2009 and cannot be applied retroactively unless
clearly intended by the legislature. As an alternative, the Court held that even if the
amendment to Minn. Stat. § 519.05 applied, the County is directed to recover benefits
pursuant to Minn. Stat. § 256B.15 and the Barg decision is controlling.
4. In re: Estate of Margaret L. Meyer, Douglas County District Court File No.: 21-PR-
11-1872 (November 16, 2012). This case has almost identical similar facts to the
Ruddick case because the Medical Assistance recipient died prior to 2009 and the
surviving spouse died in 2011.
Herbert Meyer received Medical Assistance benefits of$197,177.17 and he died in
September 2005. Prior to his death, he transferred his interest in the homestead to his
spouse, Margaret. Margaret died in August 2011. After paying funeral expenses,
Herbert’s estate consisted of $712.68. The County made a claim against Margaret’s
estate citing Minn. Stat. §§ 256B.15 and 519.05 as a basis for the claim. The personal
representative allowed the claim in the amount of $712.68.
The Court granted the Estate’s motion for summary judgment. The Court came to
similar conclusions as the Ruddick court. First, Minn. Stat. § 256B.15, subd. 2 allows
a Medical Assistance claim but recovery is limited under Barg to assets in which the
Medical Assistance recipient had an interest at the time of his death. Second, the
Court reviewed Minnesota’s spousal liability statute. The Court rejected the 2009
amendment to Minn. Stat. § 519.05(a) because the marriage ended when Herbert died
in 2005 and statutes cannot be applied retroactively. The Court then analyzed the
version of Minn. Stat. § 519.05 in effect in 2005 and determined that recovery is not
allowed under this statute because husband and wife were not “living together” at the
time that Medical Assistance benefits were paid to Herbert. Third, the Court rejected
the spousal liability statute as an alternative basis for recovering benefits because this
statute is in conflict with the more specific provision in Minn. Stat. § 256B.15.
“Therefore, as the general rule, the provisions of Minn. Stat. § 519.05 must yield to
the provisions of Minn. Stat. § 256B.15, pursuant to § 645.26, subd. 1.”Meyer at page
8. The Court applied the Perrin case in holding that the doctrine of collateral estoppel
prevents the County from relitigating Minnesota’s spousal liability statute as an
alternative theory to recovery Medical Assistance benefits.
5. In re: Estate of Merlin E. Mix, Carlton County District Court File No.: 09-PR-11-
982 (December 20, 2012). This is another “straddle case” in which the Court
disallowed the County’s claim in its entirety against the estate of the surviving
spouse. The County tried to claim that the predeceased Medical Assistance recipient
wife had an interest in the surviving spouse’s Department of Veterans Affairs benefits
received after her death. The County claimed that Minn. Stat. § 519.05 authorizes
recovery. The Court rejected this argument relying on Barg and holding that the
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