Conversion and Civil Theft in Minnesota: Why § 604.14 Is Not a Civil Version of the Criminal Theft Statute

Minnesota’s civil-theft statute reads like a gift. Sue for the value of what was taken, then collect up to that value again as punitive damages. Six subdivisions, and the punitive component is written into the cause of action rather than left to the general punitive-damages standard.

Three things about it are not what practitioners expect.

It is not the civil counterpart of the criminal theft statute. The Court of Appeals refused to import criminal theft’s breadth into § 604.14, because the word “theft” appears only in the statute’s headnote — and headnotes are not part of a Minnesota statute. A defendant who obtains your property “by swindling, whether by artifice, trick, device, or any other means” commits criminal theft under Minn. Stat. § 609.52, subd. 2(a)(4). Whether that same defendant “steals” within § 604.14 is a separate and much narrower question.

It contains no attorney-fee provision. None. The punitive multiplier is the entire fee-substitute.

And the claim that usually kills it is not in the statute at all. It is the independent-duty rule: if your interest in the property arose from a contract, both conversion and civil theft ordinarily fail no matter how deliberate the taking was.

What are the elements of conversion in Minnesota?

Two, stated at their simplest, but the supreme court has given the tort several overlapping definitions and each one carries a different limitation.

The elemental statement comes from Larson v. Archer-Daniels-Midland Co.: “The two essentials of a cause of action for conversion are property in the plaintiff, either general or special, and a conversion by defendant.” 226 Minn. 315, 317, 32 N.W.2d 649, 650 (1948). The Court of Appeals restates it as “(1) plaintiff holds a property interest; and (2) defendant deprives plaintiff of that interest.” Williamson v. Prasciunas, 661 N.W.2d 645, 649 (Minn. App. 2003) (citing Olson v. Moorhead Country Club, 568 N.W.2d 871, 872 (Minn. App. 1997)).

The supreme court’s substantive definitions, collected in Christensen v. Milbank Insurance Co., 658 N.W.2d 580, 585 (Minn. 2003):

“an act of willful interference with [the personal property of another], done, without lawful justification, by which any person entitled thereto is deprived of use and possession,” Larson v. Archer-Daniels-Midland Co., 226 Minn. 315, 317, 32 N.W.2d 649, 650 (1948), and “the exercise of dominion and control over goods inconsistent with, and in repudiation of, the owner’s rights in those goods.” Rudnitski v. Seely, 452 N.W.2d 664, 668 (Minn. 1990); accord Hildegarde, Inc. v. Wright, 244 Minn. 410, 413, 70 N.W.2d 257, 259 (1955).

Hildegarde adds the temporal element: conversion includes “an exercise of dominion over the goods which is inconsistent with and in repudiation of the owner’s right to the goods or some act done which destroys or changes their character or deprives the owner of possession permanently or for an indefinite length of time.” 244 Minn. at 413, 70 N.W.2d at 259 (as quoted in TCI Business Capital, Inc. v. Five Star American Die Casting, LLC, 890 N.W.2d 423, 428 (Minn. App. 2017)).

And there is a threshold of seriousness. Because “the measure of damages in conversion actions is the full value of the chattel at the time of the tort,” conversion is “properly limited * * * to those serious, major, and important interferences with the right to control the chattel which justify requiring the defendant to pay its full value.” Bates v. Armstrong, 603 N.W.2d 679, 682 (Minn. App. 2000) (quoting Restatement (Second) of Torts § 222A cmt. c (1965)). An interference too slight to justify making the defendant buy the item outright does not, under that standard, amount to a conversion.

Does conversion require an intent to do something wrong?

No — but it does require an intent, and the two propositions get confused constantly.

Larson says: “As a general rule, the intent, knowledge, or motive of the converter is immaterial except as affecting damages.” 226 Minn. at 317, 32 N.W.2d at 650. The Court of Appeals puts it more bluntly: “Good faith is not a defense to a claim of conversion.” Dairy Farm Leasing Co. v. Haas Livestock Selling Agency, Inc., 458 N.W.2d 417, 419 (Minn. App. 1990).

But Christensen holds that negligence is not enough. Adopting the Restatement, the court explained that conversion is “an intentional exercise of dominion or control over the chattel,” so “[m]ere nonfeasance or negligence, without such an intent, is not sufficient for conversion.” 658 N.W.2d at 585–86 (quoting Restatement (Second) of Torts § 223 cmt. b (1965)). The character of the required intent:

“The intention necessary to subject to liability one who deprives another of the possession of his chattel is merely the intention to deal with the chattel so that such dispossession results. It is not necessary that the actor intend to commit what he knows to be a trespass or a conversion. It is, however, necessary that his act be one which he knows to be destructive of any outstanding possessory right, if such there be.”

Restatement (Second) of Torts § 222 cmt. c (1965), quoted in Christensen, 658 N.W.2d at 586.

Read together: the defendant must have meant to take, hold, or deal with the item in the way that dispossessed you. He did not have to know he was doing something unlawful, and his sincere belief that the property was his own is no defense. What he cannot be liable for is an accident. In Christensen itself, a driver’s-education instructor took a school district’s van for a personal drive while intoxicated and destroyed it in a collision; the supreme court held that “the intentional dominion or control necessary for ‘conversion’ cannot be shown by accidental destruction of the vehicle in a collision, and therefore, because there is no other basis for a finding of the requisite wrongful intent, Christensen did not convert the van.” 658 N.W.2d at 586.

Can money be converted in Minnesota?

Only if it exists as an identifiable, segregated thing. Wire transfers and account balances almost certainly cannot.

TCI is the leading discussion, and it is candid about the state of the law. The plaintiff’s “claim rests on the premise that money in an intangible form is property. That premise is without precedent in Minnesota law.” 890 N.W.2d at 428. The court surveyed the supreme court’s conversion cases and found that “all the opinions of the supreme court on the subject of conversion are concerned with tangible personal property, i.e., items that can be seen and touched” — fixtures, straw, furniture, jewelry, a vehicle. Id. at 429.

For cash specifically, the Court of Appeals had already held: “Because cash is liquid and designed to be transferred, it is ‘a subject of conversion only when it is capable of being identified, and described as a specific chattel.’” Halla v. Norwest Bank Minnesota, N.A., 601 N.W.2d 449, 453 (Minn. App. 1999). Halla adds that this “is particularly true of cash deposited at a bank. Unless the deposited cash is segregated, there is no action for conversion.” Id.

TCI read Halla to mean “that a conversion claim is viable with respect to money only if the money is in a tangible form (such as a particular roll of coins or a particular stack of bills) and is kept separate from other money,” and noted that this “is consistent with the traditional common-law rule that an electronic financial transaction cannot be the basis of a conversion claim.” 890 N.W.2d at 428. The court acknowledged that other jurisdictions have expanded conversion to reach intangible property interests including bank balances — and expressly did not follow them, resolving the case on intent instead. Id.

The practical consequence: an embezzlement carried out by transfer, journal entry, or ACH is difficult to plead as conversion in Minnesota. Look to contract, unjust enrichment, breach of fiduciary duty, or fraud. See fraud and negligent misrepresentation in Minnesota. Where the transfer was made to defeat a creditor, the Uniform Voidable Transactions Act reaches conduct that conversion does not.

Is refusing to give property back a conversion?

Yes, if the refusal is unqualified. “Wrongfully refusing to deliver property on demand by the owner constitutes conversion.” Molenaar v. United Cattle Co., 553 N.W.2d 424, 430–31 (Minn. App. 1996).

Molenaar also shows how a “qualified refusal” defense actually fares. A cattle company holding a replevin order against a third party seized sixty-five heifers belonging to Molenaar. Molenaar sent purchase invoices and an identifying photograph; the company’s vice president and its attorney both refused to say where the cattle were, never asked for proof of ownership, never considered the proof he volunteered, and sold the animals out of state three weeks later. On appeal the company argued its refusal was merely conditioned on adequate proof of ownership. The court: “The facts do not demonstrate a qualified refusal; they demonstrate an absolute refusal.” Id. at 431.

Send the demand in writing, attach the proof of ownership, and date it. It converts an ambiguous holding into a documented refusal.

What does Minn. Stat. § 604.14 actually give you?

The operative subdivision, in full:

“A person who steals personal property from another is civilly liable to the owner of the property for its value when stolen plus punitive damages of either $50 or up to 100 percent of its value when stolen, whichever is greater. If the property is merchandise stolen from a retail store, its value is the retail price of the merchandise in the store when the theft occurred.”

Minn. Stat. § 604.14, subd. 1.

Four features of the rest of the section matter in practice.

No criminal case is needed. “The filing of a criminal complaint, conviction, or guilty plea is not a prerequisite to liability under this section. Payment or nonpayment may not be used as evidence in a criminal action.” § 604.14, subd. 4. Do not wait on the county attorney.

Getting the property back does not moot the claim. “The recovery of stolen property by a person does not affect liability under this section, other than liability for the value of the property.” § 604.14, subd. 5. The punitive component survives the return of the item. In Williamson, the plaintiff got her diamond jewelry back and still recovered $12,000 in statutory punitive damages. 661 N.W.2d at 652–53.

A pre-suit written demand is expressly authorized. “A person may make a written demand for payment for the liability imposed by this section before beginning an action, including a copy of this section and a description of the liability contained in this section.” § 604.14, subd. 6. Statutory demand letters are not always this well-scripted; use it.

A minor’s parent can be reached — barely. “Section 540.18 applies to this section, except that recovery is not limited to special damages.” § 604.14, subd. 3. Section 540.18, subd. 1, makes a parent or guardian of a minor under 18 living with them jointly and severally liable for the minor’s willful or malicious injury or damage “to an amount not exceeding $1,000.” By its terms the § 604.14 cross-reference carves out only § 540.18’s special-damages restriction; the $1,000 ceiling is not among the stated exceptions.

And there is no attorney-fee provision anywhere in § 604.14. Read subdivisions 1 through 6 and the words do not appear. This is the most common misconception about the statute. Compare Minn. Stat. § 8.31, subd. 3a, which does give a private plaintiff “costs and disbursements, including costs of investigation and reasonable attorney’s fees” for violations of the consumer statutes it lists. The civil-theft statute gives you up to a doubling and nothing more.

Note also the statute’s origins in retail loss prevention. Subdivision 1’s second sentence prices merchandise at retail; subdivision 2 conditions recovery for a stolen shopping cart on posted notice. TCI observed that “[t]he statute appears to be intended primarily to provide for a recovery if merchandise or other property is stolen from a retail store,” 890 N.W.2d at 430 — which helps explain why courts have not stretched “steals” to fit commercial disputes.

How have Minnesota courts construed the word “steals”?

Narrowly, and in two published Court of Appeals decisions issued within three months of each other in 2017.

In TCI, the court began: “The key word in the statute is the word ‘steals.’ . . . The legislature has not defined the word within chapter 604.” 890 N.W.2d at 430. Turning to common usage, it concluded:

“In common usage, the word ‘steals’ generally means that a person wrongfully and surreptitiously takes another person’s property for the purpose of keeping it or using it.”

Id. at 431. The court added that “[i]f the property at issue is money in an intangible form, the property is ‘used’ only if a person spends the money or invests it.” Id.

Applied to the facts — an executive who moved company funds out and back through a third party and falsified accounting entries to make a nonexistent auction look real — the court found no civil theft, because there was “no evidence that Flynn intended to keep the money at issue or that he actually kept it,” nor that he “intended to use the money at issue or that he actually used it by spending it or investing it.” Id.

The reasoning behind the narrowness is the part worth remembering. Two federal district court decisions, Damon v. Groteboer, 937 F. Supp. 2d 1048 (D. Minn. 2013), and Popp Telcom, Inc. v. American Sharecom, Inc., had read § 604.14 expansively “by incorporating the concept of criminal theft, which is broad in light of the applicable statutory definition and the accompanying caselaw.” TCI, 890 N.W.2d at 431. The Court of Appeals declined:

“But there is no textual basis for interpreting the civil-theft statute in that manner because the plain language of the statute does not use the word ‘theft.’ The word ‘theft’ appears only in the caption of the statute.”

Id. And Minnesota law makes captions inoperative. Minn. Stat. § 645.49: “The headnotes printed in boldface type before sections and subdivisions in editions of Minnesota Statutes are mere catchwords to indicate the contents of the section or subdivision and are not part of the statute.”

Three months later, Staffing Specifix, Inc. v. TempWorks Management Services, Inc., 896 N.W.2d 115 (Minn. App. 2017), aff’d on other grounds, 913 N.W.2d 687 (Minn. 2018), glossed TCI with a requirement worth pleading around: “This definition makes clear that for a person to steal something, there must be some initial wrongful act in taking possession of the property.” 896 N.W.2d at 126. The claim failed because the defendant “took possession of funds claimed by Staffing without an initial wrongful act” — the money arrived through customer invoice payments into an account the defendant owned. Id.

That is the shape of the doctrine. A defendant who obtains property lawfully and then wrongfully keeps it may commit conversion; whether he “steals” it under § 604.14 is doubtful under Staffing Specifix.

Two caveats before treating this as settled. First, TCI was not unanimous — Judge Reyes dissented on the civil-theft issue, arguing that the dictionary definitions are disjunctive and that “steal” includes “appropriating money without right or leave with the intent to make use of it wrongfully,” with “no requirement to find that the person ‘spends the money or invests it.’” 890 N.W.2d at 437 (Reyes, J., concurring in part and dissenting in part); see id. at 435 (identifying the point of departure). Second, the supreme court’s decision in Staffing Specifix addressed only the district court’s jury instruction on contract interpretation — “The issue before us is whether the district court properly instructed the jury on ‘contract meaning,’ or how to interpret contracts” — and did not review the civil-theft holding. 913 N.W.2d at 691.

One currency note. Minnesota’s criminal theft statute, Minn. Stat. § 609.52, subd. 2, was amended by Laws 2026, ch. 127, art. 7, § 4, effective August 1, 2026 and applicable to crimes committed on or after that date; the amendment deletes the medical-assistance false-claim clause formerly at subdivision 2(a)(3)(iii) (relocated to a new § 609.467) and renumbers the two clauses that followed it. That amendment does not touch civil liability, and under TCI the content of § 609.52 does not control § 604.14 in any event.

The claim-killer nobody sees coming: the independent-duty rule

If the property interest you are suing over came out of a contract, expect both the conversion count and the civil-theft count to be dismissed on summary judgment.

The rule is old. Wild v. Rarig: “when a plaintiff seeks to recover damages for an alleged breach of contract he is limited to damages flowing only from such breach except in exceptional cases where the defendant’s breach of contract constitutes or is accompanied by an independent tort.” 302 Minn. 419, 440, 234 N.W.2d 775, 789 (1975). The Court of Appeals states the test: “An independent tort may accompany a breach of contract when the defendant has a legal duty to the plaintiff arising separately from any duty imposed in the contract.” Toyota-Lift of Minnesota, Inc. v. American Warehouse Systems, LLC, 868 N.W.2d 689, 696 (Minn. App. 2015).

Staffing Specifix applied it to both tort counts at once: “Staffing’s property interests in funds it claims that respondents converted arose solely from the contracts. Any legal duty that respondents had toward funds owed to Staffing, which formed the basis of Staffing’s conversion claim, arose from the contracts. Staffing presented no evidence of an independent tort.” 896 N.W.2d at 126. The civil-theft count went out on the same ground, along with the narrow reading of “steals.” Id.

This is why so many commercial civil-theft claims fail. The plaintiff is usually a party to a contract — a services agreement, a lease, a distribution agreement — and the money at issue is money the contract said was owed. Add the money-is-not-a-chattel problem from TCI, and a business plaintiff suing a counterparty is fighting on three fronts at once.

Where the claim works is the setting the statute was built for and its close relatives: property that is tangible, identifiable, and taken by someone with no contractual claim to it at all. Williamson — jewelry left in a safe by a home seller and kept by the buyers, who lied about it for twelve years — is the paradigm. So is financial exploitation of a vulnerable adult, where the taker’s authority over the property is typically fiduciary rather than contractual.

Punitive damages: two separate tracks, and one unresolved question

Minnesota’s general punitive-damages procedure is restrictive. Minn. Stat. § 549.191:

“Upon commencement of a civil action, the complaint must not seek punitive damages. After filing the suit a party may make a motion to amend the pleadings to claim punitive damages. The motion must allege the applicable legal basis under section 549.20 or other law for awarding punitive damages in the action and must be accompanied by one or more affidavits showing the factual basis for the claim.”

The substantive standard under § 549.20, subd. 1(a) is “clear and convincing evidence that the acts of the defendant show deliberate disregard for the rights or safety of others.”

Common-law punitive damages are available for deliberate conversion of property; they are not limited to personal-injury cases. Molenaar framed the first issue as “Are punitive damages recoverable for deliberate conversion of property?”, 553 N.W.2d at 426, and answered it by reinstating a $400,000 punitive award (alongside $59,375 in compensatory damages) for the conversion of the heifers, remanding only “to the district court to complete the statutory procedures” and make the findings § 549.20, subd. 3 requires. Id. at 426, 430.

The § 604.14 punitive component is a different animal. In Williamson, the district court granted the plaintiff summary judgment for $12,000 — the value of the jewelry — plus $12,000 as § 604.14 statutory punitive damages, and separately denied her § 549.191 motion to amend to seek common-law punitive damages, reasoning that “[the statute] concerning civil liability for theft already provides for ‘punitive’ damages in the amount of 100% of the value of the stolen property” and that “the likely deterrent effect of punitive damages is satisfied by the theft statute given the nature of the conduct in this case.” The Court of Appeals affirmed both rulings. 661 N.W.2d at 652–53.

Here is the unresolved part. Section 549.191 on its face governs a motion alleging a basis “under section 549.20 or other law,” which reads broadly enough to reach a statutory punitive claim — yet Williamson involved a § 604.14 punitive award entered on summary judgment while the § 549.191 motion was denied, and the opinion does not address the tension. Until an appellate decision resolves it, do not assume either way. The safe course is to plead the § 604.14 claim as a claim for the statutory measure, and to file a § 549.191 motion promptly if you also want common-law punitive damages — being ready for the argument Williamson accepted, that the statutory doubling already does the deterrent work.

Conversion, civil theft, or replevin?

They answer different questions. Conversion and civil theft are about money; replevin is about getting the object back.

Replevin’s pre-judgment mechanics are worth knowing when the property is unique, appreciating, or about to be sold. A claimant seeking possession before final judgment “shall proceed by motion,” supported by an affidavit that must state the particular property, the facts giving rise to the right to possession, the facts showing wrongful detention, the payment history if the property is security for an obligation, the specific contractual provision if the detention rests on a non-monetary breach, and “a good faith approximation of the current market value of each item of property being claimed.” Minn. Stat. § 565.23, subd. 1. Seizure is contingent on the claimant filing a bond “in an amount which is 1-1/2 times the fair market value of the property seized,” § 565.25, subd. 1, and the respondent can generally rebond to retain or regain the property at “1-1/4 times the fair market value of the property or 1-1/2 times the amount of the claimant’s claim, whichever is less,” § 565.25, subd. 2(a). Either side may post cash or a certified check instead of a bond. § 565.25, subd. 4. The mechanics are covered in more depth in replevin and claim and delivery in Minnesota.

One warning that Molenaar delivers cleanly: a replevin order is not a license. The order there authorized the creditor to take its own cattle. Taking a third party’s cattle under cover of that order produced a conversion verdict against the creditor, and the court held that “[u]nder these facts a replevin order could not insulate United from punitive damages for intentional conversion of Molenaar’s heifers.” 553 N.W.2d at 430.

If the property is collateral and the taking was a secured party’s self-help repossession, a different framework governs entirely — see UCC Article 9 repossession and deficiency judgments in Minnesota.

How long do I have to sue?

For conversion and replevin, six years. Minn. Stat. § 541.05, subd. 1(4) sets a six-year limitation for actions:

“(4) for taking, detaining, or injuring personal property, including actions for the specific recovery thereof”

That clause is unusually well drafted for this purpose: it covers the taking (conversion), the detention (refusal on demand), and “the specific recovery thereof” (replevin) in one line.

A defendant who lies about having your property may lose the defense. In Williamson, the twelve-year gap was excused because fraudulent concealment tolled the statute. The three elements the plaintiff had to show, drawn from Haberle v. Buchwald, 480 N.W.2d 351, 357 (Minn. App. 1992): “(1) the [defendants] made a statement or statements that concealed [plaintiff’s] potential cause of action, (2) the statement or statements were intentionally false, and (3) the concealment could not have been discovered by reasonable diligence.” Williamson, 661 N.W.2d at 650–51. Critically, the test is not whether the plaintiff could have made out a prima facie case earlier: “Mere suspicion, in a case of fraudulent concealment, is not sufficient to stop the tolling of the statute of limitations.” Id. at 651.

For a civil-theft claim the answer is less clear, and the two limitation statutes point in opposite directions. Chapter 604 supplies no period of its own. Section 541.05, subd. 1(2) gives six years for an action “upon a liability created by statute, other than those arising upon a penalty or forfeiture or where a shorter period is provided by section 541.07.” And § 541.07(2) gives two years for an action “upon a statute for a penalty or forfeiture . . . .” Whether § 604.14’s express “punitive damages” component makes the claim one “upon a statute for a penalty” is a real question, and I did not locate a published Minnesota appellate decision resolving it. Until one exists, treat two years as the operative risk and file accordingly — the six-year conversion claim under subdivision 1(4) will usually cover the same conduct in any event.

Madgett Law, LLC

Madgett Law, LLC brings conversion and civil-theft claims in Minnesota state and federal court — property taken and not returned, fiduciaries and family members who kept what was not theirs, collateral seized without a right to it, and cases where a return demand is the fastest path to resolution. We assess at the outset whether a claim survives the independent-duty rule and whether the property is the kind Minnesota courts will treat as convertible, because those two questions decide most of these cases before the merits are ever reached. To discuss a matter, call 612-470-6529 or send us a message.

Sources: Minn. Stat. § 604.14, subd. 1 (liability for value when stolen plus $50 or up to 100 percent of that value; retail pricing), subd. 2 (posted-notice condition for shopping carts), subd. 3 (application of § 540.18, “except that recovery is not limited to special damages”), subd. 4 (no criminal-complaint prerequisite), subd. 5 (recovery of property does not affect liability other than for value), subd. 6 (pre-suit written demand); Minn. Stat. § 540.18, subd. 1 (parent/guardian liability for a minor’s willful or malicious conduct, capped at $1,000); Minn. Stat. § 541.05, subd. 1(2) (six years on a liability created by statute, excluding penalties and forfeitures), subd. 1(4) (six years for taking, detaining, or injuring personal property, including specific recovery); Minn. Stat. § 541.07(2) (two years upon a statute for a penalty or forfeiture); Minn. Stat. § 549.191 (punitive damages not pleaded in the complaint; motion alleging a basis under § 549.20 “or other law,” with affidavits); Minn. Stat. § 549.20, subd. 1(a) (clear and convincing evidence of deliberate disregard), subd. 3 (factors the court must weigh); Minn. Stat. § 565.23, subd. 1 (contents of the affidavit supporting a pre-judgment motion for possession); Minn. Stat. § 565.25, subd. 1 (claimant’s bond at 1-1/2 times fair market value), subd. 2(a) (respondent’s rebonding at 1-1/4 times value or 1-1/2 times the claim, whichever is less), subd. 4 (cash or certified check in lieu of bond); Minn. Stat. § 645.49 (headnotes are catchwords and not part of the statute); Minn. Stat. § 609.52, subd. 2(a)(4) (criminal theft “by swindling, whether by artifice, trick, device, or any other means”), as amended by Laws 2026, ch. 127, art. 7, § 4, effective August 1, 2026 and applicable to crimes committed on or after that date (the 2026 amendment deletes the medical-assistance false-claim clause formerly at subd. 2(a)(3)(iii), relocated to a new § 609.467, and renumbers the two clauses that followed; clause (a)(4) is unchanged); Minn. Stat. § 8.31, subd. 3a (contrast: statutory consumer claims carry costs of investigation and reasonable attorney’s fees); Christensen v. Milbank Insurance Co., 658 N.W.2d 580, 582, 585–86 (Minn. 2003) (collected definitions of conversion; Restatement (Second) of Torts §§ 222 cmt. c, 223 cmt. b; accidental destruction is not conversion); Larson v. Archer-Daniels-Midland Co., 226 Minn. 315, 317, 32 N.W.2d 649, 650 (1948) (two essentials; intent, knowledge, or motive immaterial except as to damages); Hildegarde, Inc. v. Wright, 244 Minn. 410, 413, 70 N.W.2d 257, 259 (1955) (deprivation permanently or for an indefinite length of time); Rudnitski v. Seely, 452 N.W.2d 664, 668 (Minn. 1990) (dominion and control in repudiation of the owner’s rights); Bates v. Armstrong, 603 N.W.2d 679, 682 (Minn. App. 2000) (conversion limited to serious, major, and important interferences; full-value measure); Olson v. Moorhead Country Club, 568 N.W.2d 871, 872 (Minn. App. 1997) (two elements of common-law conversion); Dairy Farm Leasing Co. v. Haas Livestock Selling Agency, Inc., 458 N.W.2d 417, 419 (Minn. App. 1990) (“Good faith is not a defense to a claim of conversion.”); Molenaar v. United Cattle Co., 553 N.W.2d 424, 426, 430–31 (Minn. App. 1996) (punitive damages for deliberate conversion of property; replevin order no shield; wrongful refusal on demand; qualified vs. absolute refusal; damages generally value at the time of conversion plus interest); Halla v. Norwest Bank Minnesota, N.A., 601 N.W.2d 449, 453 (Minn. App. 1999) (cash convertible only when identifiable as a specific chattel; unsegregated bank deposits); TCI Business Capital, Inc. v. Five Star American Die Casting, LLC, 890 N.W.2d 423, 428, 430–32, 435, 437 (Minn. App. 2017) (money in intangible form without precedent in Minnesota conversion law; retail orientation of the statute; construction of “steals”; refusal to import criminal theft; Reyes, J., concurring in part and dissenting in part at 435, 437); Staffing Specifix, Inc. v. TempWorks Management Services, Inc., 896 N.W.2d 115, 125–26 (Minn. App. 2017) (independent-duty rule applied to conversion and civil theft; “some initial wrongful act in taking possession”), aff’d on other grounds, 913 N.W.2d 687, 691 (Minn. 2018) (review limited to the contract-interpretation jury instruction); Wild v. Rarig, 302 Minn. 419, 440, 234 N.W.2d 775, 789 (1975) (contract damages limited to the breach absent an independent tort); Toyota-Lift of Minnesota, Inc. v. American Warehouse Systems, LLC, 868 N.W.2d 689, 696 (Minn. App. 2015) (independent tort requires a legal duty arising separately from the contract); Williamson v. Prasciunas, 661 N.W.2d 645, 649–53 (Minn. App. 2003) (elements of conversion; fraudulent-concealment tolling; § 604.14 valuation at the time of theft; denial of a § 549.191 amendment where statutory punitive damages were already awarded); Haberle v. Buchwald, 480 N.W.2d 351, 357 (Minn. App. 1992) (three elements of fraudulent concealment).

This article is general legal information about Minnesota law. It is not legal advice, it does not create an attorney–client relationship, and no outcome is promised or implied. Statutes, rules, and case law change; verify current authority before relying on anything here.