Justia Injury Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Jepsen v. County of Pope
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
Musta v. Mendota Heights Dental Center & Hartford Insurance Group
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
Johnson v. Darchuks Fabrications, Inc.
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
Leuthard v. Independent School District 912
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
Reetz v. City of Saint Paul
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the court of appeals concluding that Officer Eric Reetz was not entitled to defense and indemnification from his employer, the City of Saint Paul, when Reetz was sued for allegedly failing to detect a knife at a homeless shelter while working off duty as a private security guard, holding that the court of appeals erred.The City concluded that it was not obligated to defend and indemnify Reetz under Minn. Stat. 466.07 under the circumstances of this case. The court of appeals reversed. The Supreme Court reversed, holding (1) as a matter of law, Reetz was not "acting in the performance of the duties of the position" of a police officer when he allegedly failed to detect a knife that was banned only by the shelter's policies; and (2) therefore, the City was not required to defend and indemnify Reetz. View "Reetz v. City of Saint Paul" on Justia Law
Moore v. Robinson Environmental, Inc.
The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's complaint alleging that he witnessed Defendant's workers violate safety protocols resulting in contamination of his home, holding that Minn. Stat. 541.051 barred Plaintiff's claims.Plaintiff hired Defendant to remove a broken boiler that was insulated with asbestos and his asbestos pipe insulation. On March 12, 2014, a report confirmed Plaintiff's allegation that Defendant's workers tracked asbestos through Plaintiff's home. Plaintiff, however, did not sue Defendant until April 20, 2018. The district court dismissed the complaint on the grounds that the two-year statute of limitations in section 541.051 barred Plaintiff's claims. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff's damages arose out of the defective and unsafe condition of an improvement to real property, and therefore, the two-year statute of limitations in section 541.051, subdivision 1(a) barred Plaintiff's claims. View "Moore v. Robinson Environmental, Inc." on Justia Law
Koehnen v. Flagship Marine Co.
The Supreme Court held that a health care provider who did not intervene in an employee's pending workers' compensation proceeding after receiving adequate notice of the right to intervene cannot initiate a collateral attack on the compensation award under Minn. Stat. 176.271, .291 or Minn. R. 1420.1850, subp. 3B.Scott Koehnen was injured during the course and scope of his employment for Flagship Marine Company. Koehnen received chiropractic treatment from Keith Johnson. Johnson submitted his charges to the workers' compensation insurer for Koehnen's employer, but both the employer and insurer (collectively, Flagship Marine) denied liability for Koehnen's injury. When Koehnen filed a claim petition seeking workers' compensation benefits his attorney sent a notice informing Johnson of his right to intervene. Johnson, however, did not move to intervene, and the proceeding continued without him. Koehnen and Flagship Marine subsequently entered into a settlement agreement. The compensation judge approved the stipulation for settlement and issued an award on stipulation. Johnson later filed a petition for payment of medical expenses pursuant to section 176.271, .291.The compensation judge dismissed the petition, and the Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding that because Johnson chose not to intervene his petition was correctly dismissed. View "Koehnen v. Flagship Marine Co." on Justia Law
Palmer v. Walker Jamar Co.
In this wrongful death case, the Supreme Court affirmed the judgment of the court of appeals affirming the district court's grant of summary judgment for Honeywell International, holding that a claim accrues in an asbestos-related wrongful death action when the fatal disease is causally linked to asbestos.Deborah Palmer brought this action against Honeywell after her husband, Gary Palmer, died from mesothelioma. The district court dismissed the case, concluding that the statute of limitations barred Deborah's claim because she filed her action more than six years after Gary learned that exposure to asbestos had caused his mesothelioma. The court of appeals affirmed. The Supreme Court affirmed, holding (1) under DeCosse v. Armstrong Cork Co., 319 N.W.2d (Minn. 1982), wrongful death actions brought in connection with asbestos-related deaths accrue either upon the manifestation of the fatal disease in a way that it causally linked to asbestos or upon the date of death, whichever is earlier; and (2) because Deborah did not file this wrongful death action until more than six years after the claim accrued, Minn. Stat. 573.02, subd. 1 barred her claim. View "Palmer v. Walker Jamar Co." on Justia Law
Olson v. Lesch
The Supreme Court affirmed the judgment of the district court denying the motion to dismiss filed by State Representative John Lesch on a claim brought by Lyndsey Olson, Saint Paul City Attorney, for defamation per se based on statements Lesch made in a letter sent to the mayor of Saint Paul, holding that legislative immunity did not protect Lesch's letter.Lesch's letter, which was written on Lesch's official letterhead from the Minnesota House of Representatives but was marked "personal and confidential," suggested that Olson was not the right person for the position of City Attorney. Olson brought a defamation suit against Lesch, alleging that Lesch "knowingly, intentionally and maliciously made false and defamatory" statements about her in the letter. Lesch moved to dismiss the complaint, asserting that his statements were communications that were protected by legislative immunity under the Speech or Debate Clause of the Minnesota Constitution and under Minn. Stat. 540.13. The district court denied the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that neither Article IV, Section 10 nor section 540.13 extended legislative immunity to Lesch's letter. View "Olson v. Lesch" on Justia Law
Larsen v. Gannett Co., Inc.
The Supreme Court held that the fair and accurate reporting privilege protects news reports about statements on a matter of public concern made by law enforcement officers at an official press conference in an official press release.After Defendant was arrested in connection with a murder three law enforcement agencies held a press conference to announce Defendant's arrest and to discuss the investigation. That same day, the Minnesota Department of Public Safety issued a corresponding press release. Defendant was later released from jail and cleared as a suspect. Defendant sued Respondents for defamation based on their news coverage about his arrest. A jury found for Respondents. The district court set the jury verdict aside and ordered a new trial. The court of appeals reversed and reinstated the judgment for Respondents. The Supreme Court affirmed in part and reversed in part, holding (1) out of the eleven alleged defamatory statements in the news reports the fair and accurate reporting privilege applies to seven statements; and (2) the jury instructions and special verdict form did not adequately set forth the relevant factors that the jury should consider in determining whether the privilege was defeated for lack of fairness and substantial accuracy, and the error was prejudicial as to five of the seven statements. View "Larsen v. Gannett Co., Inc." on Justia Law