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Rilley v. MoneyMutual LLC

Minnesota Supreme Court
884 N.W.2d 321 (2016)

Written by Sean Carroll, JD

Facts

Scott Rilley (plaintiff) was a Minnesota resident who used MoneyMutual LLC’s (defendant) website to obtain a payday short-term loan. After an online registration and application process, which included Rilley’s home address, MoneyMutual began sending Rilley emails, including an initial email matching Rilley with a Minnesota lender. In addition, MoneyMutual used Google AdWords to display advertisements for its company when a Google user searched for phrases such as “payday loans Minnesota.” Rilley filed a class action suit in Minnesota state court, alleging that the loans MoneyMutual provided in Minnesota were illegal. MoneyMutual moved to dismiss for lack of personal jurisdiction. Rilley presented evidence that MoneyMutual sent emails to more than 1,000 Minnesota residents. The trial court denied the motion. MoneyMutual appealed.

Rule of Law

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Issue

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Holding and Reasoning (Anderson, J.)

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