Hoyt Properties, Inc. v. Production Resource Group, L.L.C.
Supreme Court of Minnesota
736 N.W.2d 313 (2007)
Hoyt Properties (plaintiff) agreed to release Production Resource Group (PRG) (defendant) as a defendant in an eviction action after settling with PRG's affiliate Entolo, relying on PRG's attorney's assurance, when asked about piercing the corporate veil between the two companies, that "There isn't anything. PRG and Entolo are totally separate." Hoyt later discovered a different lawsuit's complaint alleging facts that would support piercing that veil, and sued PRG for fraudulent misrepresentation. The trial court granted PRG summary judgment; the appellate court reversed in Hoyt's favor, and PRG sought review.
Whether a lawyer's representation may give rise to actionable claims of misrepresentation if (1) the statement implies personal knowledge of material facts, and (2) the lawyer knows the statement to be false or has no knowledge of facts supporting the statement.