Articles Posted in Injury Law

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Respondent brought suit against Appellant by service of a summons and complaint, raising claims of negligence, assault and battery. The case was pending when Minn. R. Civ. P. 5.04(a) went into effect. The case was subsequently deemed to be dismissed with prejudice under the new Rule 5.04(a). Respondent moved to vacate the judgment under Minn. R. Civ. P. 60.02, arguing that Rule 5.04(a) violated his right o procedural due process and that relief was warranted due to excusable neglect. The district court concluded that Rule 60.02 is inapplicable to a dismissal under Rule 5.04(a) or, alternatively, that Respondent failed to establish all four requirements for relief under Rule 60.02. The court of appeals reversed and remanded. The Supreme Court affirmed as modified, holding (1) Rule 60.02 applies to a dismissal under Rule 5.04(a); (2) a dismissal under Rule 5.04(a) does not violate procedural due process; and (3) the district court failed to make findings sufficient to enable appellate review of its Rule 60.02 finding. View "Gams v. Houghton" on Justia Law

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Appellant, a board-certified psychiatrist, was previously employed at the Minnesota Security Hospital in Saint Peter, Minnesota. After Appellant’s employment was terminated, Appellant filed suit against Respondents, alleging defamation and violations of the Minnesota Government Data Practices Act (MGDPA) based on statements made by the individual respondents regarding Appellant’s termination. Respondents filed a motion for summary judgment, arguing that they did not violate the MGDPA because the statements at issue were based upon public information and that the individual respondents had an absolute or qualified privilege. The district court denied the motion. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in granting summary judgment to Respondents on Appellant’s MGDPA claim; and (2) the deputy commissioner of the Department of Human Services was entitled to the protection of absolute privilege. View "Harlow v. State Dep’t of Human Servs." on Justia Law

Posted in: Injury Law

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Homeowners brought an action against a City alleging that the City’s non-employee City Engineer was negligent and caused a nuisance. The City Engineer performed the allegedly negligent acts under a contract with the City. The district court granted summary judgment to the City on the negligence claim based on vicarious official immunity but denied summary judgment on the nuisance claim, concluding that there were genuine issues of material fact for trial. The court of appeals affirmed the district court’s conclusion that the City was entitled to vicarious official immunity for the negligent design claim but reversed the denial of summary judgment on the nuisance claim, concluding that vicarious official immunity applied to the nuisance claim because the alleged nuisance arose from the same immune conduct as the alleged negligence. The Supreme Court affirmed, holding that the City was entitled to vicarious official immunity for both the Homeowners’ claims. View "Kariniemi v. City of Rockford" on Justia Law

Posted in: Injury Law

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Appellants, LaVonne and Henry Pfeil, were longstanding members of St. Matthew Lutheran Church. St. Matthew’s pastors decided to excommunicate Appellants due to their “slander and gossip” of the church’s leadership and ministry. At special voters’ meeting, the congregation voted to affirm the excommunication decision. LaVonne subsequently brought a lawsuit on behalf of herself and Henry against St. Matthew and its pastors (collectively, Respondents), asserting claims for defamation and negligence. After resolving Henry’s claims on other grounds, the district court dismissed the case with prejudice, concluding that the First Amendment deprived the court of jurisdiction to adjudicate LaVonne’s claims. The court of appeals affirmed. The Supreme Court affirmed, holding that that the First Amendment prohibits holding an organization or individual liable for statements made in the course of a religious disciplinary proceeding when those statements are disseminated only to members of the church congregation or the organization’s membership or hierarchy. View "Pfeil v. St. Matthews Evangelical Lutheran Church" on Justia Law

Posted in: Injury Law

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The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law

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Respondents, Angela Lennartson and Katie Foss, were involved in separate car accidents and recovered damages in their respective negligence actions. Subsequently, each respondent was awarded no-fault benefits from their insurer, State Farm, in arbitration proceedings under the Minnesota No-Fault Insurance Act (No-Fault Act). State-Farm moved to vacated the arbitration awards, arguing, inter alia, that collateral estoppel barred the no-fault arbitrations. The district court granted State Farm’s motion to vacate in Lennartson’s case and denied it in Foss’s case. The cases were consolidated on appeal. The court of appeals affirmed the decision in favor of Foss and reversed the decision against Lennartson, concluding that neither the No-Fault Act nor collateral estoppel barred the arbitrators’ awards of no-fault benefits to Respondents.The Supreme Court affirmed, holding (1) the No-Fault Act does not bar an insured from recovering no-fault benefits for medical expenses previously recovered in a negligence action; and (2) collateral estoppel does not bar an insured from seeking medical-expense or income-loss benefits in no-fault arbitration recovering damages for the same expenses or losses in a negligence action. View "State Farm Mut. Auto. Ins. Co. v. Lennartson" on Justia Law

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Appellant used Respondent as the general contractor for the construction of a building. When the building began having problems with water intrusion, Appellant brought suit claiming that Respondent acted negligently in its duties as general contractor. The district court granted summary judgment in favor of Respondent, concluding that the action was untimely under the two-year statute of limitations for improvements to real property in Minn. Stat. 541.051(1)(a). The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals correctly found that the plain language of section 541.051(1) does not require that construction be substantially complete to start the running of the statute of limitations; but (2) there remained a genuine issue of material fact as to when Appellant discovered its injury, and therefore, the district court erred in granting summary judgment. Remanded. View "328 Barry Avenue v. Nolan Props. Group, LLC" on Justia Law

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Sysdyne Corporation and Xigent Solutions, LLC provide staff augmentation services to companies in the engineering and information industries. When Brian Rousslang, a former employee of Sysdyne Corporation who was subject to a noncompete agreement, obtained employment with Xigent Solutions, LLC, Sysdyne sued Xigent for tortious interference with contract and sued Rousslang for breach of contract. The trial court (1) awarded damages to Sysdyne on its breach of contract claim with respect to certain preexisting customers Rousslang brought with him from Sysdyne to Xigent; but (2) ruled in favor of Xigent on the tortious interference claim, concluding that Xigent was justified in interfering with the contract because Xigent conducted a reasonable inquiry into the enforceability of the noncompete agreement and, based on advice of outside counsel, honestly believed that the agreement was unenforceable. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the justification defense to a claim of tortious interference with a contract may be satisfied by a defendant’s reliance on incorrect advice of outside counsel; and (2) under the facts of this case, the trial court did not err in concluding that Xigent met its burden of proving the justification defense. View "Sysdyne Corp. v. Rousslang" on Justia Law

Posted in: Contracts, Injury Law

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This case stemmed from the largely fraudulent lending operations of First United Funding, LLC (First United). After First United collapsed, a court-appointed Receiver commenced this action under Minnesota’s Uniform Fraudulent Transfer Act (MUFTA) against several financial institutions, including Alliance Bank and certain Respondent Banks, that had participated in First United’s loan-participation scheme. The district court (1) dismissed the claims against the Respondent Banks for failure to bring the action in a timely fashion, and (2) allowed the claim against Alliance Bank, concluding that that the Receiver had pleaded legally sufficient claims based on a “Ponzi-scheme presumption.” The district court then entered judgment against Alliance Bank. The Receiver and Alliance Bank appealed. The court of appeals (1) divided the Ponzi-scheme presumption into three separate components and concluded that the third component was unfounded in the case of Alliance Bank; and (2) concluded that the district court erred when it dismissed the Receiver’s actual-fraud claims against the Respondent Banks. The Supreme Court affirmed as modified, holding (1) all three components of the Ponzi-scheme presumption lack support in MUFTA; and (2) the Receiver failed to adequately plead constructive fraud, but the district court erred when it dismissed the Receiver’s actual fraud claims. Remanded. View "Finn v. Alliance Bank" on Justia Law

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Plaintiff’s employment at the Minnesota Office of the Secretary of State (OSS) ended when her contract was not renewed at the end of her probationary period. Plaintiff sued the State, OSS, and two government officials (collectively, Respondents), alleging common-law tort claims and statutory claims for “false statements as inducement to entering employment” under Minn. Stat. 181.64 and 181.65. Respondents moved to dismiss the claims, arguing that Plaintiff’s statutory claims against the State were barred by sovereign immunity. The district court denied the motion to dismiss in part, concluding that the Legislature waived sovereign immunity for claims brought under sections 181.64 and 181.65. The court of appeals reversed, concluding that the broad language of the statutes was insufficient by itself to subject the State to suit. The Supreme Court affirmed, holding that the State is immune from claims brought under sections 181.64 and 181.65 because the Legislature did not demonstrate a plain, clear and unmistakable intent to waive sovereign immunity for claims brought under these statutes. View "Nichols v. State" on Justia Law

Posted in: Injury Law