Justia Minnesota Supreme Court Opinion Summaries

A collision between an automobile and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. Plaintiffs, the representatives of the decedents' estates, brought wrongful death claims against BNSF, alleging negligence in the maintenance of warning signals and failure to comply with several state and federal regulations. 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 Plaintiffs' favor. A divided court of appeals reversed and remanded the matter for a new trial, concluding that the district court's 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. The Supreme Court (1) reversed the court of appeals' grant of a new trial on the ground of error in the instructions and verdict form, holding that any error did not affect the fairness and integrity of the proceedings; and (2) affirmed the district court's denial of BNSF's motion for a new trial. View "Frazier v. Burlington N. Santa Fe Corp." on Justia Law

This case arose out of the 2007 collapse of the Interstate 35W Bridge. Individual plaintiffs commenced lawsuits against two contractors that performed work on the bridge pursuant to contracts entered into with the State. The contractors brought third-party complaints against Jacobs Engineering Group on the basis that Jacobs' predecessor negligently designed the bridge. One contractor also filed a third-party complaint against the State. The State cross-claimed against Jacobs for contribution, indemnity, and statutory reimbursement. Jacobs moved to dismiss the State's cross-claim as time-barred, arguing that the reimbursement provision of the compensation statutes compensating survivor-claimants of the collapse did not retroactively revive causes of action against Jacobs that had been previously extinguished by a prior version of the statute of repose. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the provision retroactively revived the State's action for statutory reimbursement against Jacobs; (2) the provision did not violate Jacob's constitutional right to due process; and (3) revival of the action for statutory reimbursement did not unconstitutionally impair Jacobs' contractual obligations. View "In re Individual 35W Bridge Litig." on Justia Law

This case arose out of the 2007 collapse of the Interstate 35W Bridge. Individual plaintiffs commenced lawsuits against a contractor that performed work on the bridge pursuant to a contract entered into with the State. The contractor brought a third-party complaint against Jacobs Engineering Group for indemnity and contribution on the basis that Jacobs' predecessor negligently designed the bridge. Jacobs moved to dismiss the lawsuits as time-barred and argued that the 2007 amendments to Minn. Stat. 541.051 did not revive actions for contribution or indemnity that had previously been extinguished by a prior version of the statute of repose. The district court denied the motion to dismiss, but the court of appeals reversed. The Supreme Court affirmed the court of appeals, holding that the 2007 amendments to section 541.051 did not retroactively revive the contractor's action for contribution against Jacobs. View "In re Individual 35W Bridge Litig." on Justia Law

After the district court determined that the parties involved in this appeal were not in a special relationship, a jury found Appellants Eric Rolland and Rolland Building Corporation not negligent in an incident in which a skid loader attachment used to perform landscaping at Respondent Bradley Domagala's home fell on Respondent's foot, resulting in the amputation of three toes. The court of appeals affirmed in part and reversed in part, holding (1) Appellants did not have a specific legal duty to warn Respondent arising in the context of a special relationship, but (2) Appellants had a general duty to warn as an exercise of the general duty of reasonable care. The Supreme Court affirmed, holding (1) the trial court's special instructions to the jury that Appellants had no duty to warn and no duty to protect Respondent were misleading as to the crucial elements of duty and breach of duty, and (2) the instructions were prejudicial to Respondent. Remanded for a new trial. View "Domagala v. Rolland" on Justia Law

Respondent Jill Engquist, as parent and natural guardian of minor Amber Engquist, sued Appellants, Steven and Christina Loyas, for injuries Amber sustained as a result of a dog bite that occurred at Appellants' residence. The district court entered judgment in favor of Appellants after finding that Amber provoked the dog to bite her. The court of appeals reversed on the ground that the jury instruction given by the district court misstated the meaning of provocation under Minn. Stat. 347.22. The Supreme Court affirmed, holding that because the jury could have found provocation without any consideration of the victim's knowledge of the danger, the jury instructions materially misstated the law and prejudiced Respondent. Remanded for a new trial. View "Engquist v. Loyas" on Justia Law

Appellant Elaine Wesely filed a dental malpractice action, alleging that she received negligent care from dentist A. David Flor. To satisfy the statutory requirement of expert disclosure, Wesely submitted an affidavit disclosing the opinions of a doctor of internal medicine, not a dentist. After Flor moved to dismiss the claim, asserting the affidavit was deficient because the internist was not qualified to be an expert in the action, Wesely's counsel submitted a second affidavit identifying a dentist-expert and disclosing his opinions. The district court granted Flor's motion to dismiss, concluding that the second affidavit did not amend the original affidavit. The court of appeals affirmed. The Supreme Court reversed, holding that the second affidavit was an amended affidavit that was capable of correcting the alleged deficiencies of the first affidavit. Remanded. View "Wesely v. Flor" on Justia Law

Appellants were trustees of eight family trusts. After stock of closely-held corporation belonging to the trusts was fractionalized in a reverse stock split and Appellants were forced to accept cash in exchange for their shares, Appellants brought suit against the corporation. The district court dismissed all of Appellants' claims. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the valuation of the stock was not the product of common law fraud; (2) Minn. Stat. 302A.471 does not provide for dissenters' rights in the event of a reverse stock split; (3) Appellants were not entitled to equitable relief under Minn. Stat. 302A.751 because the corporation did not frustrate Appellants' reasonable expectations as shareholders; (4) merely conducting an involuntary redemption of Appellants' stock at a fair price, without more, did not constitute a breach of fiduciary duty; and (5) the district court did not err in determining the fair value of Appellants' stock when it adopted a valuation that relied in part on asset value. View "U. S. Bank N. A. v. Cold Spring Granite Co." on Justia Law

Gregory Latterell, on behalf of his stepson Jared Boom's estate, sued Progressive Northern Insurance and AIG Insurance to recover underinsured motorist (UIM) benefits following Boom's death from a motor vehicle accident. Progressive, the insurer of Boom's vehicle, denied Latterell's claim for UIM benefits because of a business-use exclusion in Boom's insurance policy. AIG, Lattrell's insurer, also denied Latterell's claim. Latterell sued, and the district court granted summary judgment to Progressive and AIG. The court of appeals affirmed, holding (1) the business-use exclusion in the Progressive policy was enforceable under the Minnesota No-Fault Automobile Insurance Act and unambiguously excluded UIM coverage under the specific circumstances of this case, and (2) Latterell could not recover UIM benefits under the AIG policy. The Supreme Court reversed the denial of Latterell's summary judgment as to Progressive, holding that Progressive's business-use exclusion was unenforceable under the No-Fault Act. Remanded with instructions to enter judgment in favor of Latterell against Progressive. View "Latterell v. Progressive N. Ins. Co." on Justia Law

After suffering a work-related injury, Employee underwent surgery at a hospital owned by HealthEast Care System. The injury required surgical implantation of a spinal cord stimulator. Employer's worker's compensation insurance provider, State Auto Insurance, paid part but not all of the surgical expenses, asserting (1) the withheld portion of the expenses was attributable to a price markup added by HealthEast to the price paid by HealthEast for the implant hardware used in Employee's surgery, and (2) the manufacturer of the implant hardware should be required to charge directly for the implant hardware. The compensation judge found that Employer and State Auto were liable for the unpaid balance. The Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding (1) HealthEast could charge for the implant hardware because when more than one health care provider is responsible for the creation of a service, article, or supply, the provider that provides the service, article, or supply in its final form is entitled to charge for it; and (2) a compensation judge does not have the authority to determine a reasonable value of a treatment, service, or supply that is lower than eighty-five percent of the provider's usual or customary charge. View "Troyer v. Vertlu Mgmt. Co." on Justia Law

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