Justia Injury Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Getz v. Peace
In this personal injury action, the Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court deducting from a damages award to Respondent the amount of discounts negotiated by Respondent's managed-care organizations, holding that the discounts were payments made pursuant to the United States Social Security Act under Minn. Stat. 548.251, subd. 1(2). After her car struck a school bus that failed to yield at an intersection, Respondent brought this action against the driver and the owner of the bus (collectively, Appellants). The medical expenses of Respondent, a medical-assistance enrollee, were covered by two managed-care organizations that contracted with Minnesota's Prepaid Medical Assistance Plan under the state's Medicaid program. The jury awarded damages, but the district court deducted from the award the discounts negotiated by the managed-care organizations. The court of appeals reversed. The Supreme Court affirmed, holding that the negotiated discounts were "payments made pursuant to the United States Social Security Act" under section 548.251, subd. 1(2), and therefore, Appellants could not offset the damages award for those payments. View "Getz v. Peace" on Justia Law
Kedrowskib v. Lycoming Engines
The Supreme Court reversed the decision of the court of appeals affirming the decision of the district court granting judgment as a matter of law to Lycoming Engines on Mark Kedrowski's claim that a defective fuel pump manufactured by Lycoming caused the airplane he was piloting to lose power and crash, holding that the district court abused its discretion by excluding that opinion of Kedrowski's sole expert on causation. The jury returned a $27.7 million verdict for Kedrowski. Thereafter, the district court granted Lycoming's motion for judgment as a matter of law, concluding that the opinion of Kedrowski's sole causation expert lacked foundational reliability and that, without this opinion, Kedrowski's claims failed. The court of appeals affirmed. The Supreme Court reversed, holding that the court's evidentiary exclusion was overbroad and an abuse of discretion. The Supreme Court remanded the case for a new trial on liability. View "Kedrowskib v. Lycoming Engines" on Justia Law
McGuire v. Bowlin
In this defamation action brought by Nathan McGuire, a public high school basketball head coach, against Julie Bowlin and three other defendants, the Supreme Court reversed the decision of the district court granting summary judgment to Bowlin solely on the basis of McGuire's status as a public official, holding that McGuire was neither a public official nor a public figure. McGuire filed this complaint alleging that Defendants had engaged in defamation and a civil conspiracy and that Bowlin had filed false maltreatment-of-minor reports. The district court dismissed all claims against all defendants. The court of appeals affirmed. On appeal, McGuire argued that he was not a public official for the purposes of his defamation claims. The Supreme Court affirmed the court of appeals' decision regarding the three defendants but reversed the decision with respect to the defamation claim against Bowlin, holding (1) McGuire was not a public official and therefore, the district court erred when it granted summary judgment on that basis; and (2) further, McGuire was not a limited-purpose public figure. View "McGuire v. Bowlin" on Justia Law
Noga v. Minnesota Vikings Football Club
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) affirming a compensation judge's judgment finding that Alapati Noga, a former defensive lineman for the Minnesota Vikings, who now suffers from dementia, was entitled to permanent and total disability benefits, holding that Noga did not satisfy the statute of limitations under Minn. Stat. 176.151. Noga played as a defensive lineman for the Vikings from 1988 until 1992. While playing for the Vikings, Noga experienced head injuries and headaches. In 2015, Noga filed a claim petition for workers' compensation benefits. A compensation judge found that Noga sustained a Gillette injury of "head trauma, brain injury, and/or dementia" that culminated on or about December 1, 1992 and that the injury was a substantial contributing factor to Noga's permanent and total disability.The WCCA vacated certain findings and remanded several issues. On remand, the compensation judge resolved those issues in Noga's favor, determining, among other things, that the statute of limitations was satisfied under Minn. Stat. 176.151 because the Vikings provided Noga with medical care that constituted a "proceeding." The WCCA affirmed. The Supreme Court reversed, holding that the Vikings' provision of care for Noga's head injuries did not constitute a proceeding that prospectively satisfied the statute of limitations. View "Noga v. Minnesota Vikings Football Club" on Justia Law
Posted in: Government & Administrative Law, Labor & Employment Law, Minnesota Supreme Court, Personal Injury
Bandemer v. Ford Motor Co.
The Supreme Court affirmed the decision of the court of appeals affirming the district court's exercise of specific personal jurisdiction over Ford Motor Company in this products liability case, holding that the claims in this case arose out of or related to Ford's contacts with Minnesota, and therefore, the exercise of specific personal jurisdiction by the Minnesota court was proper. A Ford vehicle owned by a Minnesota resident was involved in a car crash in which an airbag in the vehicle failed to deploy and a passenger was seriously injured. Ford moved to dismiss the passenger's claims for lack of personal jurisdiction, arguing that because the car involved in the accident was not designed, manufactured, or originally sold in Minnesota, Ford could not be subject to personal jurisdiction in Minnesota. The district court held that the exercise of jurisdiction over Ford was proper, and the court of appeals affirmed. The Supreme Court affirmed, holding that Ford's contacts with Minnesota were sufficient to support specific personal jurisdiction and that the reasonableness factors did not detract from the reasonableness of asserting jurisdiction over Ford in this case. View "Bandemer v. Ford Motor Co." on Justia Law
Smith v. Carver County
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the judgment of the compensation judge dismissing Petitioner's claim petition seeking workers' compensation benefits for post-traumatic stress disorder (PTSD), which Petitioner claimed resulted from numerous traumatic incidents that he experienced while working, holding that the WCCA erred. At issue on appeal was the correct interpretation of Minn. Stat. 176.011, subs.15(d), which requires an employee seeking workers' compensation benefits where the alleged injury is PTSD arising out of employment to prove that the employee has been diagnosed with PTSD by a licensed psychologist or psychiatrist using the latest version of the Diagnostic and Statistical Manual of Mental Disorders (DSM) in making a diagnosis. The Supreme Court held (1) Minn. Stat. 176.011, subs.15(d) does not require a compensation judge to conduct an independent assessment to verify that the diagnosis of the psychologist or psychiatrist conforms to the PTSD criteria set forth in the DSM before accepting the expert's diagnosis; and (2) the WCCA erred by overriding the compensation judge's choice between two competing medical experts because the expert opinion adopted by the compensation judge had an adequate factual foundation for the diagnosis. View "Smith v. Carver County" on Justia Law
Posted in: Government & Administrative Law, Labor & Employment Law, Minnesota Supreme Court, Personal Injury
Rodriguez v. State Farm Mutual Automobile Insurance Co.
In this case filed by a bus driver who sought reimbursement for chiropractic services related to her work-related injury the Supreme Court affirmed the decision of the court of appeals to reinstate Plaintiff's arbitration award after the district court vacated the award, holding that a provision in the Minnesota Workers' Compensation Act, Minn. Stat. 176.83, subd. 5(c), did not bar coverage. Plaintiff's employer's workers' compensation carrier agreed to pay workers' compensation benefits to Plaintiff but refused to pay for more than twelve weeks of chiropractic care in accordance with the treatment parameters adopted for purposes of the Act. In accordance with that decision, Plaintiff's first chiropractor stopped treatment after twelve weeks of providing care. Plaintiff then received additional care from a different chiropractor. It was for this care that Plaintiff sought reimbursement from State Farm, her personal automobile no-fault insurer. State Farm denied coverage. An arbitrator ruled in favor of Plaintiff and awarded her the full amount she sought. The district court vacated the arbitrator's award, and the court of appeals reversed. The Supreme Court affirmed, holding that the statutory prohibition on reimbursement in section 176.83, subd. 5(c) is limited to the first provider whose services the workers' compensation payer determined to be excessive. View "Rodriguez v. State Farm Mutual Automobile Insurance Co." on Justia Law
Posted in: Arbitration & Mediation, Labor & Employment Law, Minnesota Supreme Court, Personal Injury
Maethner v. Someplace Safe, Inc.
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the decision of the district court granting summary judgment to Appellants - Someplace Safe, Inc. an advocacy organization, and Jacquelyn Jorud, Respondent's former wife - in this defamation and negligence action, holding that summary judgment was properly awarded to Someplace Safe on negligence but that the question of damages required a remand. Respondent alleged that Appellants' statements accused him of committing domestic violence. The district court granted summary judgment to Appellants on the defamation claims, concluding that the statements were protected by a qualified privilege, Respondent failed to establish a genuine issue of material face on malice, and Respondent had not shown proof of actual damages. The court of appeals reversed, concluding that Respondent provided sufficient evidence of damages and breach of duty to warrant a trial on his claims. The Supreme Court held (1) Respondent's defamation claim against Jorud must be remanded to determine whether the allegedly defamatory statements involved a matter of public or private concern; and (2) no material fact questions existed about whether Someplace Safe acted with reasonable care before publishing the allegedly defamatory statements. View "Maethner v. Someplace Safe, Inc." on Justia Law
Heilman v. Courtney
The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of judgment on the pleadings to the State on Appellant's claims alleging false imprisonment and negligence, holding that the conditional release imposed under Minn. Stat. 169A.276, subd. 1(d), unambiguously begins when a Challenge Incarceration Program participant enters phase II of the program and begins living in the community. Appellant, a participant in the Challenge Incarceration Program administered by the Department of Corrections, brought this action arguing that the State failed correctly to calculate his conditional-release term and revoked his conditional release improperly after it had already ended. Specifically, Appellant argued that he was "released from prison" within the meaning of section 169A.276, subd. 1(d) when he entered phase II of that program. The district court granted the State's motion for judgment on the pleadings. The court of appeals affirmed. The Supreme Court reversed, holding that the conditional-release term imposed by section 169A.276, subd. 1(d), begins when a participant in the Challenge Incarceration Program begins living in the community. View "Heilman v. Courtney" on Justia Law
Johnson v. Darchuks Fabrication, Inc.
The Supreme Court reversed the conclusion of the Workers' Compensation Court of Appeals that the medical treatment parameters established under the Workers' Compensation Act do not apply when an employer contests its obligation under the Act to pay for an employee's particular medical treatment. Employee sought workers' compensation benefits for a work injury. Employer paid a lump sum and agreed to pay ongoing medical expenses that were reasonably required to cure and relieve Employee's symptoms. Employer paid for Employee's medical treatment until it determined that Employee's current treatment was no longer reasonable or necessary. Employee then filed a workers' compensation medical request seeking payment to cover the cost of his medications. Employer denied the request. A workers' compensation judge ordered Employer to pay for Employee's medications and treatment, holding that the treatment parameters did not apply to Employee's claim. The Workers' Compensation Court of Appeals affirmed. The Supreme Court reversed, holding (1) the ban on applying the treatment parameters in Minnesota Rule 5221.6020, subpart 2, applies only when an employer denies that it has an obligation under the Act to pay compensation for an alleged workplace injury; and (2) the workers' compensation tribunals erred in concluding that the treatment parameters did not apply to Employee's course of treatment. View "Johnson v. Darchuks Fabrication, Inc." on Justia Law