Minn. Gen. R. Prac. 114.13

As amended through October 28, 2024
Rule 114.13 - Code of Ethics and Enforcement Procedures
A.CODE OF ETHICS FOR COURT-ANNEXED ADR NEUTRALS

Introduction

Rule 114 of the Minnesota General Rules of Practice provides that alternative dispute resolution (ADR) must be considered for certain civil cases filed in district court. The ADR Ethics Board, appointed by the Supreme Court, approves individuals and Community Dispute Resolution Programs (CDRPs) that are qualified under Rule114 to act as Neutrals in court-referred cases.

This Code of Ethics governs Neutrals appointed or serving by agreement of the parties in any court-annexed ADR proceedings.

Individuals and rostered CDRPs, and individuals who volunteer for rostered CDRPs, when providing ADR services under Rules 114 or 310 of the General Rules of Practice consent to the jurisdiction of the ADR Ethics Board and to compliance with this Code of Ethics. The purpose of this Code is to provide standards of ethical conduct to guide Neutrals who provide ADR services, to inform and protect consumers of ADR services, and to ensure the integrity of the various ADR processes.

In order for ADR to be effective, there must be broad public confidence in the integrity and fairness of the process. Neutrals have a responsibility not only to the parties and to the court, but also to the continuing improvement of ADR processes. Neutrals must observe high standards of ethical conduct. The provisions of this Code should be construed to advance these objectives.

Neutrals should explain the ADR process to the parties before beginning a proceeding. Neutrals should not practice, condone, facilitate, or promote any form of discrimination on the basis of race, color, creed, religion, national origin, sex, marital status, status with regard to public assistance, disability, sexual orientation, or age. Neutrals should be aware that cultural differences may affect a party's values and negotiating style.

Failure to comply with any provision in this Code of Ethics may be the basis for the ADR Ethics Board to impose any of the remedies or sanctions set out in these rules, or for other actions by the Minnesota Supreme Court.

Violation of a provision of this Code shall not create a claim for relief or apresumption that a legal duty has been breached. Nothing in this Code should be deemed to establish or augment any substantive legal duty on the part of Neutrals.

Subdivion 1. Impartiality. A Neutral shall conduct the dispute resolution process in an impartial manner and shall serve only in those matters in which the Neutral can remain impartial . Impartiality means freedom from favoritism or bias either by word or action, and a commitment to serve all parties as opposed to a single party. If at any time the Neutral is unable to conduct the process in an impartial manner, the Neutral shall withdraw.
Subd. 2. Conflicts of Interest.
(a) A conflict of interest is a direct or indirect financial or personal interest in the outcome of the proceeding or any existing or past financial, business, professional, family or social relationship which is likely to affect impartiality or which might reasonably create an appearance of partiality or bias. The Neutral must be committed to the parties and the ADR process and not allow pressures from outside the ADR process to influence the Neutral's conduct or decisions. A Neutral shall disclose all actual and potential conflicts of interest reasonably known to the Neutral. After disclosure, the Neutral may serve, with the consent of the parties . Even with the consent of the parties, the Neutral must exercise caution in circumstances that would raise legitimate questions about the integrity of the ADR process. If a conflict of interest impairs a Neutral's impartiality, the Neutral shall withdraw regardless of the consent of the parties. Without the consent of all parties, and for a reasonable time under the particular circumstances, a Neutral who also practices in another profession shall not establish a professional relationship in that other profession with one of the parties, or any person or entity, in a substantially factually related matter.
(b) Neutrals acting as arbitrators shall disclose to the parties in writing at the time of selection, or promptly after it becomes known, any actual or potential conflict of interest known to the Neutral arbitrator.
Subd. 3. Competence. No person shall serve as a Neutral unless they possess the qualifications and ability to fulfill the role that the Neutral has been requested or assigned to serve and must decline appointment, request assistance, or withdraw when a dispute is beyond the Neutral's competence. No individual may act as a Neutral for compensation without providing the parties with a written statement of qualifications prior to beginning services. The statement shall describe the Neutral's educational background and relevant training and experience in the field.
Subd. 4. Confidentiality. The Neutral shall discuss issues of confidentiality with the parties before beginning an ADR process, including limitations on the scope of confidentiality and the extent of confidentiality provided in any private sessions that a Neutral holds with a party. The Neutral shall maintain confidentiality as required by Rules 114.08, 114.10, and 114.11 of the General Rules of Practice , and any additional agreements made with or between the parties.
Subd. 5.Quality of the Process. A Neutral shall work to ensure a quality process. A quality process requires a commitment by the Neutral to diligence and procedural fairness. A Neutral shall ensure that the reasonable expectations of the parties concerning the timing of the ADR process are satisfied and shall exert every reasonable effort to expedite the process, including prompt issuance of written reports, awards, or agreements. A Neutral shall withdraw from an ADR process or postpone a session if the process is being used to further illegal conduct, or if a party is unable to participate due to drug or alcohol abuse, or other physical or mental incapacity. A Neutral shall not knowingly make false statements of fact or law.
Subd. 6. Advertising and Solicitation. A Neutral shall be truthful in advertising and solicitation for alternative dispute resolution. A Neutral shall make only accurate and truthful statements about any alternative dispute resolution process, its costs and benefits, the Neutral's role and her or his skills and qualifications. A Neutral shall refrain from promising specific results.

In an advertisement or other communication to the public, a Neutral who is on the Roster of Qualified Neutrals may use the phrase "qualified neutral under Rule 114 of the General Rules of Practice." It is not appropriate to identify oneself as a "certified" Neutral.

Subd. 7.Fees; Requirement of Written Agreement for ADR Services; Prohibited Actions.
(a)Fees. A Neutral shall fully disclose and explain the basis of compensation, fees and charges to the parties. The parties shall be provided sufficient information about fees at the outset to determine if they wish to retain the services of a Neutral. A Neutral shall not enter into a fee agreement that is contingent upon the outcome of the alternative dispute resolution process. The fee agreement shall be included in the written agreement and shall be consistent with a court order appointing the Neutral. A Neutral shall establish a protocol for regularly advising parties on the status of their account and requesting payment of fees. If one party does not pay the fee, and another party declines to cover the fee, the Neutral may withdraw, proceed, or suspend services for both parties until payment is made. If proceeding with services, the Neutral shall not refuse participation by any party based on payment status. A Neutral who withdraws from a case shall return any unearned fee to the parties. A Neutral shall not give or receive any commission, rebate, or similar remuneration for referring a person for alternative dispute resolution services.
(b)Requirement of Written Agreement for ADR Services. In any civil or family court matter in which ADR is used, the Neutral shall enter into a signed written agreement for services with the parties either before or promptly after the commencement of the ADR process. The written agreement shall be consistent with any court order appointing the Neutral. If any court order requires the Neutral to do something that would violate these rules, the Code of Ethics for Court-Annexed ADR Neutrals, or any applicable court rules or statutes, the Neutral must decline appointment or defer appointment until the parties obtain amendment of the appointment order or obtain a subsequent order. The written agreement shall include, at a minimum, the following:
(1) A description of the role of the Neutral.
(2) If the Neutral's role includes decision making, whether the Neutral's decision is binding or non-binding.
(3) An explanation of confidentiality and admissibility of evidence.
(4) If the Neutral is to be paid, the amount of compensation, how the compensation will be paid, and include a notice that the Neutral could seek remedies from the court for non-payment pursuant to Rule 114.11(b) of the General Rules of Practice for the District Courts.
(5) If adjudicative, the rules of the process.
(6) That the Neutral must follow the Code of Ethics for Court-Annexed ADR Neutrals and is subject to the jurisdiction of the ADR Ethics Board.
(7) Neutrals for facilitative and evaluative processes shall include the following language in the agreement signed at the commencement of the process:
(A) the Neutral has no duty to protect the interests of the parties or provide them with information about their legal rights;
(B) no agreement reached in this process is binding unless it is put in writing, states that it is binding, and is signed by the parties (and their legal counsel, if they are represented) or put on the record and acknowledged under oath by the parties;
(C) signing a settlement agreement may adversely affect the parties' legal rights;
(D) the parties should consult an attorney before signing a settlement agreement if they are uncertain of their rights; and
(E) in a family court matter, the agreement is subject to the approval of the court.
(c) Prohibited Actions by Facilitative and Evaluative Neutrals. A Neutral in a facilitative or evaluative process shall not:
(1) Draft legal documents that are intended to be submitted to the court as an order to be signed by a judge or judicial officer;
(2) Regardless of a Neutral's qualifications or licenses, provide therapy to either party nor provide legal representation or advice to any party or engage in the unauthorized practice of law in any matter during an ADR process; or
(3) Require a party to stay in the ADR process or attempt to coerce an agreement between the parties.
Subd. 8.Self-Determination in Mediation. A mediator shall act in a manner that recognizes that mediation is based on the principle of self-determination by the parties.
B. RULES OF THE MINNESOTA ADR ETHICS BOARD

Introduction

(a) Application. These rules are to be applied in a manner that protects the public, instructs Neutrals, and improves the quality of court-annexed alternative dispute resolution practice under Rules 114 and 310 of the General Rules of Practice for the District Courts and the Code of Ethics for Court-Annexed ADR Neutrals in Minnesota court proceedings. To the extent possible, the remedies provided for in these rules are intended to be rehabilitative in nature.
(b)Inclusion on Roster; Revocable Privilege. Inclusion on the list of Qualified Neutrals pursuant to Minnesota General Rules of Practice 114.12 is a conditional privilege, revocable for cause.
Subdivision 1. Scope. These rules apply to complaints against any individual or community dispute resolution program subject to Rules 114 or 310 of the General Rules of Practice for the District Courts. Collaborative attorneys or other professionals as defined in Rule 111.05(a) of the Minnesota General Rules of Practice are not subject to the Code of Ethics for Court-Annexed ADR Neutrals and these rules while acting in a collaborative process under Rule 111.05, nor are court appointed special masters under Rule 53 of the Rules of Civil Procedure or court appointed experts appointed under Rule 706 of the Rules of Evidence.
Subd. 2. Procedure.
(a) Complaint.
(1) A complaint must be in writing, signed by the complainant, and submitted electronically or mailed to the ADR Ethics Board at 25 Rev. Dr. Martin Luther King Jr. Blvd., Saint Paul, MN 55155-1500. The complaint shall identify the Neutral and make a short and plain statement of the conduct forming the basis of the complaint.
(2) The ADR Ethics Board, in conjunction with the State Court Administrator's Office, shall review the complaint and determine whether the Board has a reasonable belief that the allegations(s), if true, would constitute a violation of the Code of Ethics for Court-Annexed ADR Neutrals. The ADR Ethics Board may request additional information from the complainant if it is necessary prior to making a recommendation.
(3) If the allegations(s) of the complaint, if true, would not constitute a violation of the Code of Ethics for Court-Annexed ADR Neutrals, the complaint shall be dismissed and the complainant and the Neutral shall be notified in writing. The ADR's Ethics Board's decision is final and no further review is permitted.
(b)Investigation. If the complaint is not dismissed, the Board will review, investigate, and act as it deems appropriate. In all such cases, the Board shall send to the Neutral, by electronic means, the complaint, a list identifying the ethical rules which may have been violated, and a request for a written response to the allegations and to any specific questions posed by the Board. It shall not be considered a violation of the Code of Ethics for Court Annexed ADR Neutrals, or these rules, for the Neutral to disclose notes, records, impressions, opinions, or recollections of the ADR process complained of as part of the complaint procedure. Except for good cause shown, if the Neutral fails to respond to the complaint in writing within 28 days, the allegations(s) shall be deemed admitted.
(c)Response and Decision.
(1) Upon receipt of the Neutral's response, a member of the ADR Ethics Board shall lead the investigation and shall write a report with findings and recommended actions to the Board. The Board shall determine by clear and convincing evidence whether the ethical code has been violated, and if so, determine what remedies or sanctions would be appropriate.
(2) After review and investigation, the Board shall advise the complainant and Neutral of the Board's findings, conclusions, and sanctions in writing by electronic means or U.S. Mail . If the ADR Ethics Board makes a finding that ethical violations have occurred and is imposing sanctions, the Neutral shall have the right to request reconsideration or to proceed directly to a formal hearing. If no ethical violations have been found or the complaint has been resolved informally, there is no right to a hearing.
Subd. 3.Remedies and Sanctions.
(a)Available Sanctions. The Board may impose sanctions, including but not limited to:
(1) Issue a private reprimand.
(2) Designate the corrective action necessary for the Neutral to remain on the roster.
(3) Notify the appointing court and any professional licensing authority with which the Neutral is affiliated of the complaint and its disposition.
(4) Issue a public reprimand on the ADR webpage of the Minnesota Judicial Branch website, which shall include publishing the Neutral's name, a summary of the violation, and any sanctions imposed. The public reprimand may also be published elsewhere.
(5) Remove the Neutral from the roster of Qualified Neutrals, and set conditions for reinstatement if appropriate.

In situations where the conduct is unintentional and minimal, the Board may determine that an informal remedy, including discussions with the Neutral, which may include the complainant, is appropriate to resolve the complaint in lieu of a sanction.

(b) Standards for Imposition of Sanctions. Sanctions shall only be imposed if supported by clear and convincing evidence. Conduct considered in previous or concurrent ethical complaints against the Neutral is inadmissible, except to show a pattern of related conduct the cumulative effect of which constitutes an ethical violation.
(c) Request for Reconsideration. If the ADR Ethics Board finds a violation, the Neutral may request in writing reconsideration of the findings, conclusions, and sanctions. The request shall be submitted within 14 days after the date the findings, conclusions, and sanctions are sent to the Neutral. The request shall be no longer than 2 pages in length, a copy of which must be sent to the complainant. Complainants may file a response of no longer than 2 pages in length within 7 days of notification of the Neutral's request. The Board shall address reconsideration requests in a timely manner. Requests for reconsideration will only be granted upon a showing of compelling circumstances.
(d) Review Hearing.
(1)Request for Hearing. The Neutral shall have 28 days from the date the ADR Ethics Board's findings, conclusions, and sanctions are sent to the Neutral, or 28 days from the date of the final resolution of a Request for Reconsideration, whichever is later, to request a hearing. The request for a hearing shall be in writing and be submitted to the ADR Ethics Board. The hearing will be de novo and will be limited to the ethical violations as found by the ADR Ethics Board.
(2)Appointment of the Referee. The State Court Administrator's Office shall notify the Supreme Court of the request for hearing. The court shall appoint a referee to conduct the hearing. Unless the court otherwise directs, the proceedings shall be conducted in accordance with the Minnesota Rules of Civil Procedure and Minnesota Rules of Evidence and the referee shall have all powers of a district court judge. All prehearing conferences and hearings shall be held at the Minnesota Judicial Center, shall be recorded electronically by staff of the State Court Administrator's Office, and shall not be accessible by the public.
(3)Timing of Prehearing Conference. The referee shall schedule a prehearing conference within 28 days of being appointed. Notice of this prehearing conference shall be sent to the Neutral and the ADR Ethics Board.
(4)Right to Counsel. An attorney designated by the State Court Administrator's Office shall represent the ADR Ethics Board at the hearing. The Neutral shall have the right to be represented by an attorney at the Neutral's expense.
(5)Settlement Efforts. At the prehearing conference, the referee should encourage alternative dispute resolution between representatives of the ADR Ethics Board and the Neutral.
(6)Discovery, Scheduling Order. At the prehearing conference, discovery shall be discussed. The parties shall have the right to conduct discovery, which must be completed within the time limits as set by the referee. The referee will issue a scheduling order setting forth the extent and scope and time for discovery. The scheduling order will set the hearing date and deadlines for the exchange of witness and exhibit lists. The referee may issue subpoenas for the attendance of witnesses and production of documents or other evidentiary material.
(7)Burden of Proof . At the hearing, the ADR Ethics Board has the burden to prove by clear and convincing evidence that the Neutral committed a violation of the Code of Ethics for Court-Annexed ADR Neutrals.
(8) Order . Within 60 days of the closing of the record, the referee shall issue written findings and conclusions as to whether there was a violation of the Code of Ethics for Court-Annexed ADR Neutrals. Copies of the decision shall be sent to the complainant, the Neutral, and the ADR Ethics Board. If the referee determines that there is an ethical violation, the referee may:
(A) Issue a private reprimand.
(B) Designate the corrective action necessary for the Neutral to remain on the roster.
(C) Notify the appointing court and any professional licensing authority with which the Neutral is affiliated of the complaint and its disposition.
(D) Issue a public reprimand on the Minnesota Judicial Branch website, which shall include publishing the Neutral's name, a summary of the violation, and any sanctions imposed. The public reprimand may also be published elsewhere.
(E) Remove the Neutral from the roster of Qualified Neutrals, and set conditions for reinstatement if appropriate.
(F) Require the Neutral to pay costs and disbursements and reasonable attorney fees in those cases in which it is determined that the Neutral acted in bad faith in these proceedings.
(e) Final Decision. The decision of the referee is final.
Subd. 4. Confidentiality.
(a) Public Access.
(1)Exceptions to Confidentiality. Unless and until final sanctions are imposed, all files, records, and proceedings of the Board that relate to or arise out of any complaint shall be confidential, except:
(A) As between Board members and staff;
(B) After final sanctions are imposed, upon request of the Neutral, copies of the documents contained in the file maintained by the Board, excluding its work product, shall be provided to the Neutral;
(C) As otherwise required or permitted by rule or statute;
(D) To the extent that the neutral waives confidentiality; and
(E) At the discretion of the Board, any findings, conclusions, and sanctions by the ADR Ethics Board may be provided to the complainant.
(2). Public Sanctions. If the Board designates a sanction as public , the sanction and the grounds for the sanction shall be of public record, and the Board file shall remain confidential.
(b)Prohibited Disclosure. The deliberations, mental processes, and communications of the Board and staff, shall not be disclosed.
(c) Access to District Court Records. Accessibility to records maintained by district court administrators relating to complaints or sanctions about Neutrals shall be consistent with this rule.
Subd. 5.Privilege; Immunity.
(a) Privilege. A statement made in these proceedings is absolutely privileged and may not serve as a basis for liability in any civil lawsuit brought against the person who made the statement.
(b) Immunity. Board members and staff shall be immune from suit for any conduct in the course of their official duties.

Minn. Gen. R. Prac. 114.13

Adopted effective 1/1/2023; amended effective 1/1/2023.