Olmsted v. Saint Paul Pub. Sch., No. 15-2657 (8th Cir. 2016)
Annotate this CaseAfter plaintiff attempted to unilaterally rescind his resignation and resume his teaching role, and the District refused to reinstate him, plaintiff filed suit for breach of his employment contract. The district court granted summary judgment for the District. The court rejected plaintiff's duress claim, concluding that no evidence supports the allegation that the District made an unlawful threat. Even if plaintiff could demonstrate that the District unlawfully threatened him, the threat was cured by applying the factors set forth in St. Louis Park Inv. Co. v. R.L. Johnson Inv. Co. In the absence of duress, plaintiff's resignation was valid when accepted. Plaintiff's attempted rescission of that resignation merely constitutes an offer and requires that the District provide its consent. In this case, the district did not provide consent, and plaintiff cannot unilaterally rescind his resignation. Finally, the court concluded that there is no evidence that the District made material misrepresentations to plaintiff. Accordingly, the court affirmed the judgment.
Court Description: Smith, Author, with Colloton, Circuit Judge, and Erickson, District Judge] Civil case - Contracts. Defendant was not entitled to rescind his resignation as he failed to show duress under Minnesota law; no evidence supported his allegations that the School District made an unlawful threat against him or that his will was overcome; even if an unlawful threat was made, the threat was cured as he had full knowledge of all of the facts, advice from an attorney and ample time for reflections - see St. Louis park Inv. Co. v. R.L. Johnson Inv. Co., 411 N.W.2d 288 (Minn. Ct. App. 1987); there was no evidence that the School District made material misrepresentations regarding the investigation it was conducting regarding allegations of plaintiff's misconduct.
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