Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the rulings of the compensation judge finding that C. Jeremy Lagasse was entitled to contingent fees under Minn. Stat. 176.081, subd. 1(c) and that Larry Horton was entitled to partial reimbursement of fees under Minn. Stat. 176.081, subd. 7, holding that the WCCA incorrectly applied subdivision 1(c) in its standard of review.Horton, who was injured during his employment with Aspen Waste Systems and sought permanent partial disability (PPD) benefits through Aspen's insurer (Insurer), retained Lagasse to represent him in the matter. The compensation judge determined that Lagasse was entitled to contingent fees and that Horton was entitled to partial reimbursement of fees. The WCCA reversed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the WCCA incorrectly applied subdivision 1(c); and (2) the compensation judge and the WCCA incorrectly applied subdivision 7. View "Lagasse v. Horton" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to Marvel, LLC in this negligence action, holding that an exculpatory clause purporting to release Marvel from "any and all claims" related to use of its inflatable amusement play area did not release Marvel from liability for its own negligence.Before seven-year-old Carter Justice attended a birthday party at an inflatable amusement play area owned by Marvel his mother signed a waiver of liability naming Justice. While there, Justice fell and hit his head on concrete floor, leading to several injuries. Justice sued Marvel when he turned eighteen. The district court granted summary judgment for Marvel, and the court of appeals affirmed. The Supreme Court reversed, holding that the waiver, strictly construed, did not release Marvel from liability for its own negligence. View "Justice v. Marvel, LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the order of the district court granting summary judgment to Defendants - mental healthcare providers - and dismissing Plaintiff's wrongful death action, holding that genuine issues of material fact existed.For three months, Brian Short received outpatient treatment for anxiety and depression. Thereafter, he shot and killed his wife, his three children, and himself. Plaintiff brought this wrongful death action. The district court granted summary judgment for Defendants, concluding that they did not have a duty to protect or control Brian or his wife and children absent a custodial relationship or foreseeability of harm. The court of appeals reversed, holding (1) Defendants owed a duty of care to Brian, and (2) genuine issues of material fact existed as to whether Defendants' conduct created a foreseeable risk to Brian's wife and children. The Supreme Court (1) affirmed as to Brian, holding that a mental healthcare provider owes a duty of reasonable care to its patient that is not negated by a lack of total control over the patient; and (2) reversed as to Brian's wife and children, holding that harm to the family members was outside the scope of the duty of care and unforeseeable as a matter of law. View "Smits v. Park Nicollet Health Services" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the dismissal of Appellants' claims for defense and indemnification of a federal lawsuit from the State under the State Tort Claims Act, Minn. Stat. 3.736, subd. 9, holding that Appellants were not eligible for defense and indemnification under the Act.After the Mille Lacs Band of Ojibwe sued Appellants - Mille Lacs County Attorney Joseph Walsh and Mille Lacs County Sheriff Don Lorge - in federal court Appellants sought indemnification and defense from the State. At issue was whether Appellants were "employees of the state" under the Act when the undertook the conduct that was the subject of the federal lawsuit. The district court dismissed the complaint for failure to state a claim, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) for purposes of defense and indemnification under the Act, county sheriffs generally do not act on behalf to the State when they enforce state criminal laws, and county attorneys generally do not act on behalf of the State when they prosecute state; and (2) Appellants were not acting on behalf of the State in an official capacity for purposes of defense and indemnification under the Act. View "Walsh v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming the decision of the compensation judge finding that Respondent sustained an occupational disease of hearing loss and ordering Relator to pay medical benefits under Minn. Stat. 176.135, subd. 5, holding that further proceedings were required.Respondent developed hearing loss after a career of handling occupational safety and health compliance and monitoring workplace noise levels. Respondent filed a claim for workers' compensation benefits against Relator, his most recent employer. The compensation judge ruled in favor of Respondent and denied his claim for permanent partial disability (PPD) benefits. The WCCA affirmed and clarified that the PPD issue was moot because of a Pierringer settlement between Respondent and one of his former employers. The Supreme Court remanded the case, holding (1) the occupational disease finding was supported by the evidence; (2) the award of medical benefits was appropriate under Minn. Stat. 176.135, subd. 5; and (3) the compensation judge did not properly apply the Pierringer settlement precedent, potentially prejudicing Relator's interests. View "Sershen v. Metropolitan Council" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing this insurance dispute for failure to state a claim, holding that resident-relative exclusions do not frustrate the purpose behind the abolition of interfamilial tort immunities.Appellants' son was seriously injured by a pet dog at his grandparents' residents. Appellants, on behalf of their son, filed a declaratory judgment action against Respondent after Respondent denied their claim for homeowner's insurance benefits on the basis a resident-relative exclusion in the relevant policy. In their complaint, Appellants claimed that resident-relative exclusions, inter alia, frustrate the purpose of the abolition of interfamilial tort immunities. The district court dismissed the complaint for failure to state a claim, and the court of appeals affirmed. The Supreme Court affirmed, holding that the resident-relative exclusion in the homeowner's insurance policy at issue was enforceable. View "Poitra v. Short" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of summary judgment to Respondents and dismissing Appellant's wrongful death action on grounds of common law official immunity and vicarious official immunity, holding that the court of appeals erred.Four-year-old Eric Dean was killed by his father's girlfriend following at least seven separate reports from different sources of suspected abuse of Eric. Appellant brought this action against Pope County and three child protection workers (collectively, Respondents) alleging that the child protection workers' negligence in performing their duties under the Reporting of Maltreatment of Minors Act (RMMA), Minn. Stat. 626.556, was the proximate cause of Eric's death. The district court granted summary judgment for Respondents on immunity grounds. The court of appeals affirmed. The Supreme Court reversed, holding (1) the RMMA abrogated the defense of official immunity as to duties undertaken to comply with subdivisions 10 and 11 of section 626.556 or related rules and provisions of law; (2) statutory discretionary function immunity under Minn. Stat. 466.03, subd. 6 did not apply in this case; and (3) a genuine issue of material fact existed precluding summary judgment. View "Jepsen v. County of Pope" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) upholding a compensation judge's order requiring Employer to reimburse Employee for medical cannabis, holding that the WCCA erred.Employee was injured while working for Employer. After multiple rounds of medical intervention proved to be unsuccessful, Employee's doctor certified her for participation in the state's medical cannabis program. Employee sought reimbursement for the cost of the cannabis from Employer. Employer asserted in response that the federal prohibition in the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, on the possession of cannabis preempted the requirement under Minnesota law that an employer pay for an injured employee's medical treatment when that treatment is medical cannabis. The WCCA declined to address the preemption argument and upheld the compensation judge's order. The Supreme Court reversed, holding (1) the WCCA lacked subject matter jurisdiction to determine the preemption issue; and (2) the CSA preempted the compensation court's order mandating Employer to pay for Employee's medical cannabis. View "Musta v. Mendota Heights Dental Center & Hartford Insurance Group" on Justia Law

The Supreme Court reversed the judgment of the Workers' Compensation Court of Appeals (WCCA) affirming the determination of the compensation judge that Respondent's treatment with opioid medication for a work-related ankle injury that resulted in a pain condition was compensable as a rare case exception, holding that the rare case exception to the treatment parameters did not apply.The opioid medication in this case was non-compliant with the long-term opioid medication parameter promulgated by the Department of Labor & Industry for that form of treatment. At issue was whether the medication was compensable under the workers' compensation laws as a "rare case" exception. The Supreme Court held that the rare case exception did not apply because the circumstances of this case were not exceptional and thus reversed the decision of the WCCA. View "Johnson v. Darchuks Fabrications, Inc." on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) vacating factual findings made by the workers' compensation judge regarding the reasonableness and necessity of an employee's medical treatment for work-related injuries, holding that the WCCA erred.Respondent received a Gillette-style injury to her neck and upper spine. Respondent was later notified by her former employer, Appellant, that it would no longer approve reimbursement for certain injections. A compensation judge determined that the injections were neither necessary nor reasonable. The WCCA reversed, concluding that the decision of the compensation judge was not supported by substantial evidence in the record. The Supreme Court reversed, holding that the WCCA erred in (1) vacating the workers' compensation judge's factual findings; and (2) directing the compensation judge to consider whether Respondent's case presented rare circumstances warranting an exception from the treatment parameters. View "Leuthard v. Independent School District 912" on Justia Law