Justia Minnesota Supreme Court Opinion Summaries

The Johnsons, organic farmers, claimed that while Appellant, a cooperative, was spraying pesticide onto conventionally farmed fields adjacent to the Johnsons' fields, some pesticide contaminated the Johnsons' organic fields. The Johnsons sued Appellant on theories including trespass, nuisance, and negligence per se, seeking damages and injunctive relief. The district court granted summary judgment to Appellant and dismissed all of the Johnsons' claims. The court of appeals reversed. The Supreme Court (1) concluded that the Johnsons' trespass claim and claim for damages based on 7 C.F.R. 205.202(b) failed as a matter of law, and therefore, reversed the court of appeals' reinstatement of those claims; and (2) held that the district court failed to consider whether the Johnsons' non trespass claims that were not based on section 205.202(b) could survive summary judgment, and therefore, affirmed the court of appeals' reinstatement of those claims. Remanded. View "Johnson v. Paynesville Farmers Union Coop. Oil Co." on Justia Law

John Doe 76C (Doe) claimed the Archdiocese of St. Paul and Minneapolis and the Diocese of Winona (Dioceses) were liable for his damages resulting from alleged sexual abuse in the early 1980s by a priest under the Dioceses' control. Doe's claims were subject to six-year statutes of limitations. To support his argument that accrual of his claims was delayed and that his action was timely, Doe intended to offer general expert testimony on the theory of repressed and recovered memory. The district court concluded that Doe's expert testimony was inadmissible under the Frye-Mack standard, making his claims untimely, and granted the Dioceses summary judgment. The court of appeals reversed, concluding that Doe's expert testimony might be admissible under Minn. R. Evid. 702. The Supreme Court reversed, holding that Doe's expert testimony on the theory of repressed and recovered memory, offered to prove a disability delaying the accrual of a cause of action, was inadmissible under Rule 702 because it lacked foundational reliability and, as a result, Doe's claims were untimely. View "John Doe 76C v. Archdiocese of St. Paul & Minneapolis" on Justia Law

This case required the Supreme Court to decide whether an airplane manufacturer owed a duty to a noncommercial pilot who, after purchasing an airplane from the manufacturer but failing to receive all of the flight training promised to him as part of that purchase, died when his airplane crashed. The district court found the manufacturer was negligent. The court of appeals reversed, concluding that the manufacturer did not have a duty to provide training and that the claims were barred by the educational malpractice doctrine. The Supreme Court affirmed, holding (1) the manufacturer did not owe a duty to the pilot, and thus the district court erred in its judgment; and (2) accordingly, the Court did not reach, among other things, the issues of educational malpractice or causation. View "Glorvigen v. Cirrus Design Corp." on Justia Law

This case required the Supreme Court to interpret the Minnesota dog owner's liability statute. Respondent Gordon Anderson was injured during an attack on his dog by another dog named Bruno, owned by Respondent Neil Christopherson. Anderson, along with his wife, sued Christopherson and his father, arguing, among other claims, that the Christophersons were strictly liable for Anderson's injuries under Minn. Stat. 347.22. The district court granted partial summary judgment to the Christophersons, holding (1) the Christophersons were not liable under the statute because Bruno's conduct was not focused on Anderson; and (2) Dennis Christopherson was not liable because he was not an "owner" of Bruno, as that term was defined under the statute. The court of appeals reversed, holding (1) a dog owner may be held strictly liable for injuries caused by a dog's affirmative conduct regardless of the focus of that conduct; and (2) there were genuine issues of material fact as to whether Anderson's injury was a direct and immediate result of Bruno's conduct and whether Dennis Christopherson was an owner of Bruno under the statute. The Supreme Court affirmed and remanded for a jury trial on both the question of whether Anderson's injuries were caused by Bruno's conduct under section 347.22 and also the question of whether Dennis Christopherson was an "owner" of Bruno under the statute. View "Anderson v. Christopherson" on Justia Law

Tammy Pepper suffered injuries in a single-vehicle accident when she was struck by a pickup truck owned by her sister and driven by her stepfather. Pepper subsequently sought insurance benefits under three policies. First, Pepper sought and recovered liability benefits from her sister's insurer. Second, Pepper sought and recovered liability benefits from her stepfather's insurer, State Farm. Third, Pepper sought, but did not recover, underinsured motorist coverage under a separate State Farm policy held by her stepfather. State Farm denied that it owed Pepper underinsured motorist coverage under the stepfather's policy on the ground that the terms of that policy excluded the sister's truck from its definition of vehicles eligible for underinsured motorist coverage. The district court granted summary judgment to State Farm, concluding that the exclusion in the stepfather's policy was valid because the exclusion was designed to prevent coverage conversion. The court of appeals reversed. The Supreme Court reversed, holding that the district court was correct that Pepper was not entitled to UIM benefits in this case. View "Pepper v. State Farm Mut. Auto. Ins. Co." on Justia Law

Relator Minh Nguyen was injured after falling from a ladder while employed by Audio Communications. Nguyen filed an amended petition to seek benefits for permanent total disability, but his petition did not seek to establish the date of onset of permanent disability. After a compensation judge awarded Nguyen benefits from March 4, 2008, for permanent total disability, Audio Communications petitioned the compensation judge for determination of the date of onset. The judge found that Nguyen became permanently and totally disabled as of March 1, 2007. Nguyen then petitioned to require Audio Communications to pay the attorney fees he incurred in partially succeeding in opposing Audio Communications' petition for determination of the date of onset of permanent total disability. The compensation judge denied the claim for attorney fees, and the WCCA affirmed. The Supreme Court affirmed, holding that an employer is not liable for the attorney fees incurred by an injured employee in successfully defending against the employer's petition to offset social security disability benefits paid to the employee against benefits paid by the employer for permanent total disability, where the employee's attorney fees can be paid from ongoing workers' compensation benefits paid to the employee. View "Nguyen v. Audio Commc'ns" on Justia Law

A collision at a railroad crossing between a vehicle and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. The representatives of the decedents' estates brought separate wrongful death claims against BNSF. During trial, the district court instructed the jury, without objection from BNSF, to apply a common-law or "reasonable person" standard of care. The jury returned a verdict in appellants' favor. BNSF moved for a new trial, contending that the trial court erred by not applying the standard of care established by applicable federal regulations. The court of appeals concluded that the jury instruction and special verdict form using a common-law duty of care constituted plain error that substantially affected BNSF's rights and the fairness and integrity of the proceedings and remanded the matter. The Supreme Court reversed, holding that any error in the instructions and verdict form did not affect the fairness and integrity of the proceedings. View "Frazier v. Burlington N. Santa Fe Corp." on Justia Law

Christopher Daly sued Zachary McFarland for injuries sustained from an accident. The jury returned a special verdict form finding that both Daly and McFarland were negligent, but that Daly's negligence was not a direct cause of the accident. The jury then allocated thirty percent of the fault for the accident to Daly. The district court entered judgment for Daly in the amount of $442,633, the full amount of damages that the jury found Daly to have suffered. McFarland moved for judgment as a matter of law, arguing that the court improperly reconciled the jury's special verdict form answers, and that McFarland was not negligent as a matter of law. In the alternative, McFarland moved for a new trial. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court abused its discretion in reconciling the special verdict form; and (2) because the jury found McFarland to be at least seventy percent causally negligent for the accident, the case was remanded with directions to enter a remittitur awarding Daly $309,843, and if Daly rejected the remittitur, to grant a new trial on liability issues. View "Daly v. McFarland" on Justia Law

Plaintiff Alice Ann Staab brought suit against Defendant Diocese of St. Cloud for injuries she sustained on premises Defendant owned and operated. A special jury verdict attributed fifty percent of the negligence to the sole defendant and fifty percent of the negligence to a nonparty to the lawsuit. The district court ruled that Minn. Stat. 604.02, subd. 1 does not apply in an action against only one defendant and ordered Defendant to pay the entire damages award. The court of appeals reversed, holding that under the plain language of section 604.02, subdivision 1, Defendant must pay only in proportion to the percentage of fault attributed to Defendant by the jury. The Supreme Court affirmed but under a different analysis, holding (1) section 604.02, subdivision 1, applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor and limits the amount collectible from the defendant to its percentage share of the fault assigned to it by the jury; and (2) consequently, Defendant must pay Plaintiff fifty percent of the jury award, Defendant's share of the fault as determined by the jury. View "Staab v. Diocese of St. Cloud" on Justia Law

Employee was injured in a work-related accident in Minnesota and then moved to Wyoming where she received medical treatment. The Wyoming medical providers submitted their charges to Employer's workers' compensation insurer. Relying on Minn. Stat. 176.136, subd. 1b(d), the insurer made payments in the amount provided under the workers' compensation benefit structure in Wyoming. Employee filed a workers' compensation medical request for the unpaid balance, arguing that Minn. Stat. 176.135, subd. 1 was controlling. The workers' compensation judge agreed and found for Employee. The workers' compensation court of appeals reversed. The Supreme Court affirmed, holding (1) Minn. Stat. 176.136, subd. 1b(d) limits a Minnesota employer's workers' compensation liability to an out-of-state medical provider to the amounts provided in the workers' compensation schedule of benefits in the state where the provider is located; and (2) section 16.136, subd. 1b(d) was not unconstitutional as applied. View "Schatz v. Interfaith Care Ctr." on Justia Law