**IN THE DISTRICT COURT OF THE STATE OF MINNESOTA

______ JUDICIAL DISTRICT
COUNTY OF [COUNTY]**

Court File No.: ____

COMPLAINT

(Personal Injury – Premises Liability / Slip‐and‐Fall)

[// GUIDANCE: This template is drafted to comply with Minnesota premises-liability standards, Rule 8 pleading requirements, the modified comparative-fault statute (Minn. Stat. § 604.01), and all generally applicable notice and verification provisions. Replace every bracketed placeholder before filing.]

TABLE OF CONTENTS

1. Parties…………………..……………………………………………………… ¶¶ 1–2
2. Jurisdiction & Venue………………..…………………………………… ¶¶ 3–5
3. Factual Allegations………………..……………………………………… ¶¶ 6–13
4. Cause of Action: Negligence (Premises Liability)…… ¶¶ 14–22
5. Damages………………………………………………………………………… ¶¶ 23–26
6. Demand for Jury Trial………………………………………………… ¶ 27
7. Prayer for Relief…………………………………………………………… ¶ 28
8. Reservation of Rights………………………………………………… ¶ 29
9. Verification…………………………………………………………………… p. 10
10. Signature Block…………………………………………………………… p. 11

I. PARTIES

1. Plaintiff. [PLAINTIFF FULL LEGAL NAME] (“Plaintiff”) is an individual resident of [CITY], [COUNTY] County, Minnesota, and is competent to sue in his/her/their own right.

2. Defendant. [DEFENDANT FULL LEGAL NAME] (“Defendant”) is a [Minnesota corporation / limited liability company / individual] with its principal place of business at [ADDRESS] in [COUNTY] County, Minnesota, and at all relevant times owned, leased, managed, and/or controlled the premises located at [PREMISES ADDRESS] (the “Premises”).

II. JURISDICTION AND VENUE

3. This Court has subject‐matter jurisdiction pursuant to Minn. Const. art. VI, § 3 and Minn. Stat. § 484.01, because this is a civil action for personal injuries exceeding $15,000.

4. Personal jurisdiction over Defendant is proper because Defendant resides in, is domiciled in, transacts business in, and/or committed tortious conduct in Minnesota.

5. Venue is proper in this County under Minn. Stat. § 542.09 because the cause of action arose in this County and/or Defendant resides or maintains its registered office here.

III. FACTUAL ALLEGATIONS

6. On or about [DATE OF INCIDENT] at approximately [TIME], Plaintiff lawfully entered the Premises as a(n) [invitee/licensee] for the purpose of [BUSINESS PURPOSE/REASON FOR VISIT].

7. At that time, an [ice‐covered / wet / debris‐strewn / uneven] surface (the “Dangerous Condition”) existed in [SPECIFIC LOCATION ON PREMISES].

8. Defendant created the Dangerous Condition and/or had actual or constructive notice of it for a sufficient time to remedy or warn of the hazard.

9. Defendant failed to inspect, maintain, and/or warn of the Dangerous Condition, in violation of its duty to keep the Premises in a reasonably safe condition for foreseeable users.

10. As Plaintiff traversed the [sidewalk / aisle / staircase], Plaintiff slipped and fell due to the Dangerous Condition, violently striking the [BODY PARTS].

11. Plaintiff immediately experienced severe pain, was transported to [HOSPITAL NAME], and has since undergone [MEDICAL TREATMENT SUMMARY].

12. As a direct and proximate result of Defendant’s acts and omissions, Plaintiff has incurred medical expenses, lost wages, pain, suffering, and other general and special damages.

13. All conditions precedent, including any applicable notice requirements, have been performed, have occurred, or have been waived.

IV. CAUSE OF ACTION

Negligence – Premises Liability (Minnesota Common Law)

14. Plaintiff realleges and incorporates by reference ¶¶ 1–13.

15. Defendant owed Plaintiff a duty of reasonable care to maintain the Premises in a condition that was reasonably safe and free from unreasonable risks of harm.

16. Defendant breached that duty by, inter alia:
     a. Failing to remove or remediate the Dangerous Condition;
     b. Failing to inspect and/or monitor the Premises adequately;
     c. Failing to provide warnings, signage, or barriers; and
     d. Violating applicable building, safety, and maintenance standards.

17. Defendant knew or, in the exercise of reasonable care, should have known of the Dangerous Condition and the foreseeable risk of harm it posed to lawful entrants.

18. Defendant’s breach was the direct and proximate cause of Plaintiff’s injuries.

19. Plaintiff was exercising reasonable care for his/her/their own safety at all relevant times.

20. Pursuant to Minn. Stat. § 604.01 (2023), Plaintiff’s fault, if any, was less than 51 percent of the total fault, and recovery is therefore not barred.

21. Plaintiff seeks all damages recoverable under Minnesota law, including without limitation: medical expenses (past and future), lost earnings and earning capacity, pain and suffering, emotional distress, loss of the enjoyment of life, and other general and special damages.

22. Plaintiff also seeks prejudgment and post-judgment interest as allowed by Minn. Stat. § 549.09 (2023), together with taxable costs, disbursements, and allowable statutory fees.

V. DAMAGES

23. Past Medical Expenses: approximately $[AMOUNT] and continuing.

24. Future Medical Expenses: estimated at $[AMOUNT], subject to proof at trial.

25. Lost Wages / Diminished Earning Capacity: $[AMOUNT], subject to supplement per Minn. R. Civ. P. 26.05.

26. Non-Economic Damages: Pain, suffering, emotional distress, and loss of enjoyment of life in an amount to be determined by the trier of fact, but believed to exceed $50,000.

VI. DEMAND FOR JURY TRIAL

27. Pursuant to Minn. R. Civ. P. 38.01 and the Seventh Amendment to the United States Constitution as incorporated through the Fourteenth Amendment, Plaintiff hereby demands a trial by jury on all issues so triable.

VII. PRAYER FOR RELIEF

28. WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in favor of Plaintiff and against Defendant as follows:
     a. For an award of past and future medical expenses in an amount proven at trial;
     b. For an award of past and future lost wages and diminished earning capacity;
     c. For general damages for pain, suffering, emotional distress, and loss of enjoyment of life;
     d. For prejudgment and post-judgment interest as allowed by law;
     e. For Plaintiff’s taxable costs, disbursements, and statutory fees;
     f. For such limited injunctive relief as the Court deems just and proper to abate the Dangerous Condition for the protection of the public; and
     g. For such other and further relief as the Court deems just and equitable.

VIII. RESERVATION OF RIGHTS

29. Plaintiff reserves the right to amend this Complaint to conform to the evidence, add additional parties, or assert additional claims pursuant to Minn. R. Civ. P. 15.

VERIFICATION

I, [PLAINTIFF NAME], declare under penalty of perjury that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint and know the contents thereof; and that the same is true of my own knowledge, except as to those matters alleged on information and belief, and as to those matters, I believe them to be true.

Executed on __, 20____, at [City], Minnesota.

[PLAINTIFF NAME]
Plaintiff

SIGNATURE BLOCK

Respectfully submitted,

[LAW FIRM NAME]
By: ____
[ATTORNEY NAME], Esq. (Bar No. ______)
[ADDRESS]
[City, State ZIP]
Phone: [PHONE]
Email: [EMAIL]

ATTORNEY FOR PLAINTIFF

[// GUIDANCE: Attach the Minnesota Civil Cover Sheet, Rule 104 Certificate of Representation and Parties, and any other district‐specific administrative forms when filing. Verify local scheduling orders and early mediation requirements in the selected county.]