Justia Minnesota Supreme Court Opinion SummariesArticles Posted in Injury Law
Staab v. Diocese of St. Cloud
Alice Staab sued Diocese of St. Cloud for negligence. The jury awarded compensatory damages of $224,200, attributing fifty percent of the negligence that caused Alice’s injuries to the Diocese and fifty percent to Alice’s husband, Richard. Richard was not named as a party in the lawsuit. The district court entered judgment for $224,200 against the Diocese, concluding that Minn. Stat. 604.02(1), which limits liability for a severally liable person, does not apply when only one defendant is named in a lawsuit. The Supreme Court reversed, holding that section 604.02(1) applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor. On remand, the district court entered judgment against the Diocese for the entire damages award, concluding that an uncollectible share of damages attributable to a nonparty tortfeasor can be reallocated under Minn. Stat. 604.02(2). The court of appeals affirmed the reallocation. The Supreme Court reversed, holding that a party who is severally liable under section 604.02(1) cannot be ordered to contribute more than that party’s equitable share of the total damages award through the reallocation-of-damages provision in section 604.02(2). Remanded. View "Staab v. Diocese of St. Cloud" on Justia Law
Schmitz v. U.S. Steel Corp.
Respondent filed a complaint against his former employer, U.S. Steel Corporation, alleging retaliatory-discharge and threat-to-discharge claims under the Workers’ Compensation Act. The district court granted U.S. Steel’s pretrial motion to quash Respondent’s demand for a jury trial on the retaliatory-discharge claim. After a bench trial, the district court entered judgment for Respondent on his threat-to-discharge claim and rejected Respondent’s retaliatory-discharge claim. The court of appeals affirmed in part and reversed in part, concluding (1) Respondent’s retaliatory-discharge claim, which sought only money damages, was legal rather than equitable in nature, and therefore, Respondent was entitled to a jury trial on that claim; and (2) the district court correctly denied U.S. Steel’s motion seeking to assert a Faragher/Ellerth affirmative defense to vicarious liability for Respondent’s threat-to-discharge claim. The Supreme Court affirmed, holding (1) Respondent had the right to a jury trial on his retaliatory-discharge claim; and (2) U.S. Steel may not assert a Faragher/Ellerth affirmative defense to Respondent’s threat-to-discharge claim. View "Schmitz v. U.S. Steel Corp." on Justia Law
Leiendecker v. Asian Women United of Minn.
Sinuon and Lawrence Leiendecker, husband and wife, were involved in litigation with Asian Women United of Minnesota (AWUM), a nonprofit organization, for a decade. In this lawsuit, the fifth suit between the parties,the Leiendeckers sought to recover for injuries allegedly inflicted by AWUM and other defendants through the suits the defendants brought against the Leiendeckers in the past. AWUM moved for dismissal under Minnesota’s anti-SLAPP statutes. The district court denied AWUM’s anti-SLAPP motion, concluding that the allegations in the Leiendeckers’ complaint were sufficient to defeat the motion. The Supreme Court reversed, holding that the anti-SLAPP statutes required the Leiendeckers to produce evidence to defeat the anti-SLAPP motion rather than rely solely on the allegations in their complaint. View "Leiendecker v. Asian Women United of Minn." on Justia Law
Minke v. City of Minneapolis
Plaintiff applied for a job within the Mounds View Police Department, which commenced a background investigation. Mounds View contacted the Minneapolis Police Department, where Plaintiff previously worked, and interviewed Sergeant Janice Callaway, one of Plaintiff’s former supervisors, who allegedly made defamatory statements about Plaintiff. Plaintiff subsequently sued Callaway and the City of Minneapolis for intentional interference with prospective economic advantage and for defamation. The district court granted Defendants’ motion for summary judgment with respect to the intentional interference claim but allowed the defamation claim to proceed. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not err in denying summary judgment on the defamation claim, as absolute privilege did not apply to the allegedly defamatory statements made by Callaway. View "Minke v. City of Minneapolis" on Justia Law
Doe v. Brandon
In 2005, Paul Alan Brandon, a church volunteer who was an ordained Assemblies of God minister, sexually abused Plaintiff. In 2011, Plaintiff filed a negligence action against the Minnesota District Council of the Assemblies of God (“District Council”) because it recommended the renewal of the ministerial credentials of Brandon. The district court granted summary judgment in favor of the District Council on the negligence claim, concluding that the District Council did not owe Plaintiff a duty of care. The court of appeals reversed, determining that there was sufficient evidence for a jury to conclude that the District Council’s conduct created a foreseeable risk of injury to a foreseeable plaintiff, and thus, under Domagala v. Rolland, the District Council owed Plaintiff a duty of care, even in the absence of a special relationship. The Supreme Court reversed, holding, as a matter of law, that the District Council had no duty to Plaintiff, as there was no special relationship between the District Council, and Plaintiff and the District Council did not create a foreseeable risk of injury to a foreseeable plaintiff. View "Doe v. Brandon" on Justia Law
Poppler v. Wright Hennepin Coop. Elec. Ass’n
Plaintiffs, owners of a dairy farm, sued Wright-Hennepin Cooperative Electric Association for stray voltage that allegedly injured their herd of dairy cows. The jury found that Wright-Hennepin had been negligent, had created a nuisance, and had trespassed and returned a special verdict awarding Plaintiffs $753,200 in damages. Wright-Hennepin moved, post-trial, that the district court issue supplemental findings itemizing the $753,200 judgment. The district court granted the motion. The court of appeals affirmed in part, reversed in part, and remanded for a new trial on the issue of damages, determining that the district court lacked authority to amend the judgment to itemize the jury’s damages award. The Supreme Court affirmed, holding that the district court had no authority, by rule or by inherent power, to amend the judgment to itemize the jury’s damages award. View "Poppler v. Wright Hennepin Coop. Elec. Ass’n" on Justia Law
Gieseke, on behalf of Diversified Water Diversion, Inc., v. IDCA, Inc.
John Gieseke, on behalf of Diversified Water Diversion, Inc., filed a complaint against IDCA, Inc., asserting claims for, inter alia, tortious interference with Diversified’s prospective economic advantage. The district court found for Diversified on the tortious interference claim and awarded $220,000 in damages. IDCA filed motions for judgment as a matter of law and for a new trial or remittitur, asserting (1) Minnesota does not recognize a cause of action for tortious interference with a prospective economic advantage; (2) even if such a tort were available, Diversified failed to show a reasonable expectation of economic advantage; and (3) the damages awarded in this case were excessive. The district court denied the post-trial motions. The court of appeals affirmed. The Supreme Court reversed and vacated the judgment on the tortious interference claim, holding (1) tortious interference with prospective economic advantage is a viable claim in Minnesota; but (2) Diversified’s claim failed as a matter of law because Diversified failed to specifically identify any third parties with whom it had a reasonable expectation of a future economic relationship and failed to prove damages caused by the wrongful interference with such a relationship. Remanded. View "Gieseke, on behalf of Diversified Water Diversion, Inc., v. IDCA, Inc." on Justia Law
Fernow v. Gould
A snowplow driver for the City of Alexandria collided with Donald Fernow's vehicle. Fernow brought a personal injury action against the City. At the same time, Fernow's insurance company (Insurer) sought arbitration against the City, seeking repayment in basic economic loss benefits paid to Fernow. In the personal injury action, the district court denied the City's motion for summary judgment on the basis that Fernow's claim was barred by statutory discretionary immunity, common law official immunity, and statutory snow and ice immunity. The court of appeals affirmed. Meanwhile, the arbitrator awarded Insurer basic economic loss benefits, concluding that the defense of governmental statutory immunity did not apply to the matter because of the denial of the City's motion for summary judgment. The district court confirmed the award. The court of appeals reversed, concluding that the arbitrator exceeded her authority when she determined that the defense of governmental statutory immunity did not apply to the matter. The Supreme Court affirmed on different grounds, holding that claims of immunity, including necessary questions of fact, should be determined by the district court prior to arbitration on the merits under the Minnesota No-Fault Automobile Insurance Act. Remanded.View "Fernow v. Gould" on Justia Law
Vassallo v. Majeski
Respondent was injured when Hennepin County Sheriff’s Deputy Jason Lee Majeski’s emergency vehicle struck Respondent’s vehicle as Majeski was responding to an emergency call. Respondent commenced a personal injury lawsuit against Majeski and Hennepin County, alleging negligence by Majeski and vicarious liability on the part of the County. The district court held that because Majeski was responding to an emergency at the time of the accident, Majeski’s conduct was protected by official immunity as a matter of law, and accordingly, the County was protected by vicarious official immunity. The court of appeals reversed and remanded for trial, concluding that a jury must determine whether Majeski proceeded cautiously through the intersection as required by public safety. The Supreme Court reversed, holding (1) Majeski did not, as a matter of law, violate a ministerial duty in his conduct while traveling through the intersection, and Majeski’s conduct was not willful or malicious; and (2) therefore, Majeski was entitled to official immunity and the County was entitled to vicarious official immunity. Remanded. View "Vassallo v. Majeski" on Justia Law
Sipe v. STS Mfg., Inc.
Appellant was discharged after testing positive to a drug test. Nearly three years after being discharged, Appellant filed an action against Respondents, his former employers, alleging that Respondents violated various provisions of the Drug and Alcohol Testing in the Workplace Act, namely Minn. Stat. 181.953. Respondents filed a motion to dismiss, asserting that Appellant's claim was barred by the two-year statute of limitations in Minn. Stat. 451.07(1) for, inter alia, libel, slander, "or other tort resulting in personal injury." The district court granted the motion, concluding that a claim under section 181.953(10) was a "tort resulting in personal injury." The court of appeals affirmed. The Supreme Court reversed, holding (1) Appellant's claim was subject to the six-year statute of limitations under Minn. Stat. 541.05(1)(2) as a cause of action "upon liability created by statute"; and (2) therefore, Appellant's complaint was not time-barred. Remanded. View "Sipe v. STS Mfg., Inc." on Justia Law