Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals denying Appellants' petition for a writ of mandamus after the district court denied Appellants' motion to transfer venue or, an the alternative, their motion asserting forum non conveniens, holding that the term "several" as used in the context of venue motions means "separate."In this medical malpractice case, Appellants, the two defendants, filed a motion for a change of venue under Minn. Stat. 542.10, which allows "several defendants residing in different counties" to compel the transfer of venue when the majority of them wish to transfer venue. In denying the motion, the district court concluded that the two defendants did not constitute several defendants under the statute. The court of appeals agreed and denied Appellants' petition for a writ of mandamus. The Supreme Court reversed, holding that the word "several" in section 54.10 means "separate." View "Manselle v. Krogstad" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the district court's dismissal of a medical malpractice action brought against a hospital system based on the alleged negligence of independent contractors involved in providing care for a patient in the emergency rooms of two different hospitals owned by the hospital system, holding that a hospital can be held vicariously liable for the negligence of an independent contractor based on the doctrine of apparent authority.In granting the hospital system's motion to dismiss, the district court ruled that a hospital is not vicariously liable for the acts of non-employees. The court of appeals affirmed. The Supreme Court reversed, holding that a plaintiff states a vicarious liability claim against a hospital for the professional negligence of independent contractors in the hospital's emergency room based on a theory of apparent authority if the hospital held itself out as a provider of emergency medical care and the patient looked to the hospital, rather than a specific doctor, for care and relied on the hospital to select the physical and other medical professionals to provide the necessary services. View "Popovich v. Allina Health System" on Justia Law

In this medical malpractice case, the Supreme Court reversed the decision of the court of appeals concluding that the district court abused its discretion by admitting testimony about causation from Dr. John Stark, an orthopedic surgeon, and Dr. Kevin Stephan, an infection-disease specialist, holding that the district court did not abuse its discretion in admitting the doctors' causation testimony.This action arose from right-knee arthroplasty Dr. James Schaffhausen performed on Plaintiff. In her complaint, Plaintiff argued that, as a result of the surgery, she suffered permanent neurologic damage. The jury found for Plaintiff. Dr. Schaffhausen moved for judgment as a matter of law or a new trial, arguing that it was error for Dr. Stark and Dr. Stephan to testify as to causation because they were not neurologists. The district court denied the motions. The court of appeals reversed, concluding that the experts were not qualified to testify as to causation because they lacked the requisite occupational experience in neurology. The Supreme Court reversed, holding that where the district court carefully weighed the qualifications of Dr. Stark and Dr. Stephan before deciding to admit their testimony, the court did not abuse its discretion in admitting their testimony on the issue of causation. View "Marquardt v. Schaffhausen" on Justia Law

Plaintiff sued Defendants, health care providers, alleging professional negligence. Defendants filed a motion to compel authorization of an informal discussion with the surgeon who performed the Plaintiff’s surgery. The surgeon was not named as a defendant. Upon Plaintiff’s motion, the district court issued a protective order requiring Plaintiff to authorize the surgeon to participate in the informal discussion but restricting Defendants’ questioning of the surgeon to his own treatment of Plaintiff. Defendants filed an interlocutory appeal. Meanwhile, the parties and the surgeon participated in an informal discussion. While the interlocutory appeal was pending, the case was tried to a jury. The district court allowed the surgeon to opine on matters other than his own treatment of Plaintiff. The jury found in favor of Defendants. Thereafter, the court of appeals proceeded to decide the interlocutory appeal and reversed the district court’s protective order, concluding that Defendants were allowed to ask the surgeon about Defendants’ care of Plaintiff and the cause of her injury. The Supreme Court vacated the court of appeals’ opinion, holding that the court of appeals lacked appellate jurisdiction over the interlocutory order. View "Howard v. Svoboda" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

Plaintiffs filed suit against Defendants for medical malpractice. Defendants moved to dismiss the complaint for insufficient process and and insufficient service of process. The district court (1) denied the motions to dismiss for insufficient process, concluding that, although the summons and complaint were defective due to the lack of a Minnesota attorney’s signature, the Minnesota Rules of Civil Procedure granted the court discretion to allow the summons and complaint to be cured by amendment; and (2) denied the motions to dismiss for insufficient service of process as to some defendants, finding those defendants to have been validly served, but granted the motions with respect to the remaining defendants. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the summons and complaint bearing only the signature of an attorney not licensed to practice in Minnesota were defective, but the district court did not abuse its discretion in allowing them to be amended; and (2) Plaintiffs in this case produced sufficient evidence of effective service, and Defendants did not satisfy their burden to prove that service was not effective, and therefore, the district court erred in granting Defendants’ motion to dismiss for insufficient service. View "DeCook v. Olmsted Med. Ctr., Inc." on Justia Law

Plaintiffs filed suit against Defendants for medical malpractice. Defendants moved to dismiss the complaint for insufficient process and and insufficient service of process. The district court (1) denied the motions to dismiss for insufficient process, concluding that, although the summons and complaint were defective due to the lack of a Minnesota attorney’s signature, the Minnesota Rules of Civil Procedure granted the court discretion to allow the summons and complaint to be cured by amendment; and (2) denied the motions to dismiss for insufficient service of process as to some defendants, finding those defendants to have been validly served, but granted the motions with respect to the remaining defendants. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the summons and complaint bearing only the signature of an attorney not licensed to practice in Minnesota were defective, but the district court did not abuse its discretion in allowing them to be amended; and (2) Plaintiffs in this case produced sufficient evidence of effective service, and Defendants did not satisfy their burden to prove that service was not effective, and therefore, the district court erred in granting Defendants’ motion to dismiss for insufficient service. View "DeCook v. Olmsted Med. Ctr., Inc." on Justia Law

Respondents, on behalf of their six-year-old daughter, Jocelyn, alleged that Appellants, a medical doctor and medical center, negligently failed to diagnose Jocelyn's cancer and that if they had timely diagnosed Jocelyn's cancer, her cancer would have been curable. But, Respondents asserted, because of the delayed diagnosis, it was likely Jocelyn's cancer would be fatal. The district court granted summary judgment in favor of Appellants, concluding (1) Minnesota law does not permit a patient to recover damages when a physician's negligence causes the patient to lose only a chance of recovery or survival; and (2) Respondents' proof of causation failed as a matter of law. The court of appeals reversed the grant of summary judgment in favor of Appellants. The Supreme Court affirmed, holding (1) Minnesota law permits recovery for "loss of chance" in a medical malpractice action; and (2) Respondents created a genuine issue of material fact on the issue of causation. View "Dickhoff v. Green" on Justia Law