Justia Minnesota Supreme Court Opinion Summaries

David Miller purchased a home owned by respondents Linda Lankow and Jim Betz. The home had previously been extensively remediated because of moisture intrusion damage. Respondents Donnelly Brothers and Total Service Company and defendant Diversified Contractors, Inc. did the remediation work. After discovering and notifying respondents and defendants of additional moisture intrusion damage, buyer began to repair the home. Buyer then commenced an action against respondents and defendant to recover damages. The district court excluded buyer's expert witness evidence as a sanction for the spoliation of evidence that resulted from buyer starting to make repairs to his home. The court then granted respondents' summary judgment motion on the basis that buyer could not make a prima facie case without the expert evidence. The court of appeals affirmed. The Supreme Court reversed, holding that the duty of a custodial party to preserve evidence may be discharged when the custodial party has a legitimate need to destroy the evidence and gives the noncustodial party notice sufficient to enable the noncustodial party to protect itself against the loss of the evidence. View "Miller v. Lankow" on Justia Law

Employee was injured while working in Minnesota for Wisconsin-based Employer. Employee applied for Wisconsin and Minnesota workers' compensation benefits. Employer's insurance company, Travelers Insurance, covered the Wisconsin benefits but denied the claim for Minnesota benefits based on an exclusion of Minnesota coverage in Employee's policy. Employee then filed a claim for Minnesota benefits with the Minnesota Department of Labor and Industry. After settling the claim, the Department pursued a petition for reimbursement it had filed against Employer. A compensation judge found that Employer was not insured for Minnesota workers' compensation liability and ordered Employer to reimburse the Department. The Workers' Compensation Court of Appeals (WCCA) reversed, concluding that Employer was entitled to coverage from Travelers under the reasonable expectations doctrine. On review, the Supreme Court reversed and remanded for reconsideration in light of a recent Court decision clarifying that the doctrine should not be used to provide coverage in contravention of unambiguous policy terms. On remand, the WCCA again reversed the compensation judge. On review, the Supreme Court reversed, holding that the WCCA had no authority to declare unambiguous language of an insurance contract to be invalid and unenforceable because the exclusion conflicted with Wisconsin statutory provisions and public policy. View "Martin v. Morrison Trucking, Inc." on Justia Law

While Timothy Allen worked as a sales associate for respondent Burnet Realty, he executed agreements to participate in respondent's legal administration program (LA Program). Under the LA Program contracts, Allen and respondent agreed to an allocation of expenses should a dispute arise related to Allen's work for respondent. In litigation commenced after he stopped working for respondent, Allen claimed that respondent violated Minn. Stat. 60K.47 because the LA Program contracts were insurance, and, as a result, respondent was required to be, but was not, authorized to engage in the business of insurance in Minnesota. Allen also claimed other relief on the basis that the contracts were insurance. The district court granted summary judgment in favor of respondent, concluding that the contracts were not contracts of insurance. The court of appeals affirmed. The Supreme Court affirmed the grant of summary judgment to respondent, holding that the LA Program was not "insurance" under statutory definitions on statute or case law. View "Allen v. Burnet Realty, L.L.C. " on Justia Law

After meeting with Robert Swendra, an insurance agent selling American Family Insurance products, Curtis Graff purchased an automobile policy and an umbrella policy. Based on Swendra's representations, Graff wrongfully believed the umbrella policy contained $1 million in underinsured motorist (UIM) coverage. Later, Graff injured his back in a car accident with an underinsured motorist. Graff filed a complaint alleging breach of contract against American Family and negligent procurement of insurance coverage against the Swendra Agency. After Graff entered into a settlement agreement with American Family Graff's contract claim against American Family was dismissed, and the negligence claim against the Swendra Agency proceeded to trial. The jury found Swendra Agency liable and awarded damages. Pursuant to the collateral source statute, the district court reduced the damages award by $200,260. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the court of appeals did not err in finding that Graff's release of American Family did not extinguish Graff's claim against the Swendra Agency, and (2) the district court properly excluded the attorney fees paid to Graff's counsel from the collateral source calculation. View "Graff v. Robert M. Swendra Agency, Inc." on Justia Law