Justia Minnesota Supreme Court Opinion Summaries

An Insurer issued a life insurance policy to an Insured. After the Insured died, the Insurer refused to pay the death benefit to Plaintiff, the Insured’s widow, and rescinded the life insurance policy based on its discovery that the Insured had failed to disclose that he had undergone certain medical procedures. Plaintiff sued the Insurer and the medical records contractor from whom the Insurer requested the Insured’s medical records. The district court granted summary judgment to Defendants, concluding (1) the Insured’s failure to disclose the medical procedures made his statements willfully false or intentionally misleading as a matter of law; and (2) a patient does not have a cause of action under Minn. Stat. 144.298(2) for withholding a medical record that the patient authorized to be released. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) rescission of a life insurance policy requires proof of the insured’s subjective intent to deceive, and there was a genuine issue of material fact regarding the intent of the Insured in this case; and (2) a patient does not have a private right of action under section 144.298(2) when a person releases fewer medical records than authorized by a patient’s consent. View "Larson v. Northwestern Mut. Life Ins. Co." on Justia Law

In 1984 and 1985, James Stevens injured both shoulders while working for S.T. Services and CNA Insurance Companies (collectively, S.T. Services). In 1994, Stevens and S.T. Services entered into a stipulation for settlement under which the parties agreed that Stevens was permanently totally disabled and would receive ongoing permanent total disability benefits. A compensation judge entered an award on the stipulation, and Stevens received benefits until 2011. Stevens began working as a plumbing specialist in 2008 and disclosed his job to S.T. Stevens but continued to receive workers’ compensation benefits. In 2011, S.T. Services filed a petition with the Workers Compensation Court of Appeals (WCCA) to discontinue paying benefits on the grounds that Stevens was no longer permanently totally disabled. A compensation judge granted S.T. Services’ petition to discontinue, and the WCCA affirmed. The Supreme Court reversed, holding that S.T. Services was not allowed by statute to file a petition to discontinue benefits under the circumstances of this case. View "Stevens v. S.T. Servs." on Justia Law

A subcontractor on a public project filed suit against the general contractor and an insurance company that provided a payment bond seeking to recover money owed under the subcontract after the general contractor defaulted. The subcontractor asserted a payment-bond claim against the insurance company and breach of contract, unjust enrichment, and other claims against the general contractor. The insurance company filed a motion for summary judgment on the payment-bond claim because the subcontractor mailed its pre-suit notice of claim to the general contractor listed on the subcontract rather than the address listed on the payment bond. The district court denied the motion and granted judgment against the insurance company. The court of appeals reversed. The Supreme Court affirmed, holding (1) pursuant to Minn. Stat. 574.31(2)(a), a claimant must serve notice on the contractor at its address as stated in the bond as a prerequisite to filing suit; and (2) the subcontractor in this case did not comply with the statutory notice requirements. View "Safety Signs, LLC v. Niles-Wiese Constr. Co., Inc." on Justia Law

Appellants hired Respondent as the general contractor to build a seasonal residence on Appellant's property. Respondent purchased a general liability insurance policy from Midwest Family Mutual Insurance Company that included an absolute pollution exclusion. Respondent later purchased a boiler for Appellant's home that bore a label warning that the boiler was designed to run on natural gas only. Respondent connected the boiler to a liquid propane line. Appellants were later transported to hospital due to carbon monoxide poisoning from the boiler. Appellants brought litigation against Respondent. Midwest initiated a declaratory judgment action, requesting that the district court find Midwest had no duty to defend or indemnify Respondent because coverage was barred under the absolute pollution exclusion. The district court denied Midwest's motion for summary judgment, concluding that it would be inappropriate to rule as a matter of law that the absolute pollution exclusion barred coverage under the facts in this case since Respondent did not cause any environmental pollution. The court of appeals reversed, holding that carbon monoxide constitutes a pollutant in the Midwest policy. The Supreme Court affirmed, holding that carbon monoxide released from a negligently installed boiler is clearly a "pollutant" that is subject to the absolute pollution exclusion of the Midwest policy. View "Midwest Family Mut. Ins. Co. v. Wolters" on Justia Law

In 2002, Employee suffered injuries in a work-related accident and was rendered a paraplegic. Employer and its insurer accepted liability for Employee's injuries and paid various workers' compensation benefits. In 2010, Employee filed a medical request seeing payment for the installation of a ceiling-mounted motorized lift system. A compensation judge (1) determined that the cost of making the structural changes was compensable under Minn. Stat. 176.135 because those changes were necessary to provide Employee with reasonable and necessary medical treatment, and (2) ordered Employer and its insurer to pay for the modifications in their entirety. The workers' compensation court of appeals reversed, concluding that the changes to Employee's home necessary to permit installation of the lift system constituted "alteration or remodeling" of Employee's home and that Employer's liability was therefore limited by Minn. Stat. 176.137. The Supreme Court affirmed, holding that the cost of the structural modifications to Employee's residence that were necessary to permit the ceiling-mounted track system to be installed were "alteration or remodeling" costs subject to section 176.137 and were not costs of medical treatment. View "Washek v. New Dimensions Home Health & State Fund Mut. Ins. Co. " on Justia Law

Second Chance Investments, LLC (SCI) purchased a fire insurance policy from Auto-Owners Insurance Company (Auto-Owners) that covered a building with the limit of insurance set at $2,095,500. The building subsequently suffered extensive fire damage. SCI filed a proof of loss claiming the building was a total loss. Auto-Owners rejected the proof of loss, contending that it did not state the actual cash value of the loss as required by the policy or provide a written estimate of repair to support the claim. After a continued dispute over whether the property was a total loss, Auto-Owners ultimately filed a complaint in district court seeking an order compelling SCI to submit the issue of whether the building was a total loss to a binding determination by an appraisal panel. The district court denied Auto-Owners' motion to compel appraisal and dismissed its complaint. The court of appeals affirmed, concluding that a court, rather than an appraisal panel, is the appropriate forum to determine whether the property suffered a total loss. The Supreme Court affirmed, holding that a party to a fire insurance policy does not have the statutory right to have an appraisal panel decide whether a claim involves a total loss. View "Auto-Owners Ins. Co. v. Second Chance Invs., LLC" on Justia Law

Respondent sued Appellants for negligence and resulting injuries sustained in a car accident. The parties entered into a tentative settlement subject to Respondent giving her underinsured motorist (UIM) carrier notice under Schmidt v. Clothier to preserve her potential UIM claim. The UIM carrier elected to substitute its check for the tortfeasor's check pursuant to Schmidt-Clothier. Respondent accepted the substitute check. The negligence claim proceeded to trial, where a jury found Appellants negligent. The district court entered judgment in favor of Respondent and the UIM carrier. The court of appeals affirmed the judgment for Respondent but reversed for the UIM carrier. The Supreme Court affirmed the reversal of the judgment in favor of the UIM carrier but reversed the court of appeals' decision affirming the judgment for Respondent, holding that an injured party may not continue to pursue a negligence claim against the tortfeasor after she has agreed to settle the negligence action under the Schmidt-Clothier procedure and has accepted the substituted check from the UIM carrier. View "Isaac v. Ho" on Justia Law

L.H. Bolduc Company, Inc. (Bolduc) was the subcontractor of Engineering and Construction Innovations, Inc. (ECI). Bolduc damaged a sewer pipe while working on a construction project. ECI repaired the damage and sought reimbursement from Bolduc's insurer, The Travelers Indemnity Company of Connecticut (Travelers) under an endorsement to Bolduc's policy naming ECI as an additional insured for liability caused by acts or omissions of Bolduc. Travelers denied coverage. ECI subsequently sued Bolduc and Travelers (collectively, Appellants) for negligence and breach of contract. A jury found that Bolduc was not negligent, and the district court granted summary judgment for Appellants on ECI's breach of contract claims, concluding that Appellants had no obligation to reimburse ECI for damages not caused by Bolduc. The court of appeals reversed, determining (1) ECI was entitled to coverage as an additional insured without regard to Bolduc's fault; and (2) Bolduc was required to indemnity ECI. The Supreme Court reversed, holding (1) ECI did not qualify as an additional insured with respect to the pipe damage; and (2) Bolduc could not be required to indemnify ECI without violating Minn. Stat. 337.02, which prohibits indemnification for the fault of others in construction contracts. View "Eng'g & Constr. Innovations, Inc. v. L.H. Bolduc Co., Inc." on Justia Law

Policyholder obtained a title insurance policy from Insurer for a parcel of property it owned. Because an ambiguity in the legal description of the property prevented Policyholder from reselling the property, Policyholder filed an action seeking a declaration of Insurer's obligations under the policy and alleging breach of contract against Insurer. The district court held in favor of Policyholder, concluding that Insurer was liable because the title to the property was unmarketable. The court, however, limited Policyholder's recovery to the face value of the policy. The court of appeals affirmed the finding of liability but held that Policyholder was entitled to recovery in excess of the policy limit. The Supreme Court (1) affirmed the district court's grant of partial summary judgment to Policyholder on the question of Insurer's liability for its failure to defend and indemnify Policyholder; but (2) reversed the court of appeals' award of damages to Policyholder in excess of the policy limit and remanded for reinstatement of the district court's award of damages. View "Mattson Ridge, LLC v. Clear Rock Tile, LLP" on Justia Law

In this subrogation action, appellant Insurer sought to recover payments it made to its Insured for the repair of water damage allegedly caused by the negligence of respondent, the commercial tenant of Insured. The district court dismissed Insurer's subrogation claim as a matter of law, relying on the court of appeals decision in United Fire & Casualty Co. v. Bruggeman. The court of appeals affirmed. The Supreme Court reversed after rejecting the rule from Bruggeman, holding that the question of whether an insurer may pursue a subrogation action against the tenant of an insured, when the tenant's negligence caused damage to the insured's property, must be answered by examining the unique facts and circumstances of each case. Remanded. View "RAM Mut. Ins. Co. v. Rusty Rohde" on Justia Law