## Facts

- Thomas J. Cameron founded Synergistic Technologies Business Systems, Inc. (Syntech) in 1983, initially operating it from the basement of Judith M. Olson’s home.
- Olson provided various services to or for Syntech over time, including financial, consulting, and legal work, sometimes without pay.
- Olson alleged Cameron repeatedly promised she would receive a 50% ownership interest in Syntech in exchange for her contributions; Cameron denied making such promises.
- In 1995, Cameron terminated Olson’s employment with Syntech.
- Cameron later sold Syntech to PowerCerv Corporation for cash and stock; Olson received no ownership interest and sued to obtain a share of the value transferred.

## Issues

1. Whether Minn. Const. art. I, § 4 guarantees a jury trial on a promissory-estoppel claim.
2. Whether Minn. R. Civ. P. 38.01 entitles a party to a jury trial on promissory estoppel because the plaintiff seeks monetary relief.

## Decision

- The Minnesota Supreme Court affirmed the denial of a jury trial on Olson’s promissory-estoppel claim.
- The Court held there is no constitutional jury-trial right because promissory estoppel is equitable and not a cause historically triable to a jury at the time the Minnesota Constitution was adopted.
- The Court held Rule 38.01 does not independently confer a jury-trial right for promissory estoppel merely because money is demanded.
- By affirming the court of appeals, the Court left in place the reversal of the trial court’s $60,000 equitable award to Olson.

## Legal Principles

- The Minnesota constitutional right to a civil jury trial is limited to causes of action that were triable to a jury at common law when the Minnesota Constitution was adopted (1857).
- Promissory estoppel is treated as an equitable doctrine for jury-trial-right purposes, even when it is used to seek monetary relief.
- Whether a claim is jury-triable turns on the nature of the cause of action (legal vs. equitable) under the historical test, not solely on the remedy requested.
- Minn. R. Civ. P. 38.01 implements the constitutional jury-trial right and does not expand it to equitable claims simply because the plaintiff seeks money.

## Conclusion

The court held that promissory estoppel is an equitable claim outside Minnesota’s constitutional jury-trial guarantee and that Rule 38.01 does not create a jury right based only on a request for money damages, affirming the denial of a jury trial and leaving the plaintiff without the trial court’s equitable monetary award.


Olson v. Synergistic Techs. Bus. Sys., 628 N.W.2d 142 (Minn. 2001)