Articles Posted in Minnesota Supreme Court

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In this negligence lawsuit filed against Kraemer Construction, Inc., the Supreme Court held that Kraemer and Ulland Brothers, Inc. were engaged in a common enterprise as a matter of law when Richard Washburn was killed and that the election of remedies provision required dismissal of the suit. Jessica Kelly, as trustee for the next-of-kin of Washburn, filed this lawsuit against Kraemer for its alleged negligence in causing Washburn’s death by electrocution at a construction site. Kraemer moved for summary judgment, arguing that it was engaged in a common enterprise with Ulland, Washburn’s employer, when Washburn was killed and that the election-of-remedies provision of the Minnesota Workers’ Compensation Act prevented Kelly from bringing a civil action against Kraemer when her children had already recovered workers’ compensation benefits from Ulland. The court of appeals reversed the district court’s denial of summary judgment and remanded for entry of summary judgment in favor of Kraemer. The Supreme Court affirmed, holding that Kraemer and Ulland were engaged in a common enterprise and that the election of remedies provision required dismissal. View "Kelly v. Kraemer Construction, Inc." on Justia Law

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Minn. Stat. 554.02, a section of Minnesota’s anti-SLAPP law, is unconstitutional as applied to claims at law alleging torts. Petitioners sued Asian Women United of Minnesota (AWUM), a nonprofit organization, seeking to recover under a number of legal theories of injuries allegedly inflicted by AWUM through four previous lawsuits. AWUM moved for dismissal under Minnesota’s anti-SLAPP law. Minn. Stat. 554.01-.06. The district court dismissed all of Petitioners’ claims with the exception of their claim for malicious prosecution. The district court concluded that Minn. Stat. 554.02 - the section of the law that governs motions “to dispose of a judicial claim” - violated Petitioners’ right to a jury trial by requiring the trial judge to find facts. As a result, the district court denied AWUM’s motion to dismiss. The Supreme Court affirmed, holding that section 554.02 is unconstitutional when it requires a district court to make a pretrial finding that speech or conduct is not tortious under Minn. Stat. 554.03, as was the case here. View "Leiendecker v. Asian Women United of Minnesota" on Justia Law

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Jerry Expose underwent therapy at Thad Wilderson & Associates, P.A. (the Clinic). During one of his therapy sessions with Nina Mattson, an unlicensed intern-therapist, Expose made statements that threatened serious injury to a particular individual. Mattson reported the threats, and a jury found Expose guilty of making terroristic threats. The court of appeals reversed, concluding that the therapist-client privilege prohibited Mattson from testifying about information she learned during Expose’s therapy sessions. Before appealing, Expose filed suit against the Clinic and Mattson (collectively, Appellants). The district court concluded that Appellants were immune from liability under the common law doctrine of absolute privilege. The court of appeals reversed on all issues except the immunity under the doctrine of absolute privilege as to the testimony from the criminal trial. The Supreme Court affirmed, holding (1) an unlicensed intern-therapist has no statutory duty to disclose to law enforcement information regarding a serious threat of physical violence made against an identifiable person; (2) the doctrine of absolute privilege does not shield the disclosures made by an unlicensed intern-therapist to law enforcement and to prosecutors; and (3) a consent form notifying a client of the client’s rights under the Minnesota Health Records Act does not authorize the release of the client’s medical records. View "Expose v. Thad Wilderson & Associates, P.A." on Justia Law

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Respondent brought suit against Appellant by service of a summons and complaint, raising claims of negligence, assault and battery. The case was pending when Minn. R. Civ. P. 5.04(a) went into effect. The case was subsequently deemed to be dismissed with prejudice under the new Rule 5.04(a). Respondent moved to vacate the judgment under Minn. R. Civ. P. 60.02, arguing that Rule 5.04(a) violated his right o procedural due process and that relief was warranted due to excusable neglect. The district court concluded that Rule 60.02 is inapplicable to a dismissal under Rule 5.04(a) or, alternatively, that Respondent failed to establish all four requirements for relief under Rule 60.02. The court of appeals reversed and remanded. The Supreme Court affirmed as modified, holding (1) Rule 60.02 applies to a dismissal under Rule 5.04(a); (2) a dismissal under Rule 5.04(a) does not violate procedural due process; and (3) the district court failed to make findings sufficient to enable appellate review of its Rule 60.02 finding. View "Gams v. Houghton" on Justia Law

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Appellant, a board-certified psychiatrist, was previously employed at the Minnesota Security Hospital in Saint Peter, Minnesota. After Appellant’s employment was terminated, Appellant filed suit against Respondents, alleging defamation and violations of the Minnesota Government Data Practices Act (MGDPA) based on statements made by the individual respondents regarding Appellant’s termination. Respondents filed a motion for summary judgment, arguing that they did not violate the MGDPA because the statements at issue were based upon public information and that the individual respondents had an absolute or qualified privilege. The district court denied the motion. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in granting summary judgment to Respondents on Appellant’s MGDPA claim; and (2) the deputy commissioner of the Department of Human Services was entitled to the protection of absolute privilege. View "Harlow v. State Dep’t of Human Servs." on Justia Law

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Homeowners brought an action against a City alleging that the City’s non-employee City Engineer was negligent and caused a nuisance. The City Engineer performed the allegedly negligent acts under a contract with the City. The district court granted summary judgment to the City on the negligence claim based on vicarious official immunity but denied summary judgment on the nuisance claim, concluding that there were genuine issues of material fact for trial. The court of appeals affirmed the district court’s conclusion that the City was entitled to vicarious official immunity for the negligent design claim but reversed the denial of summary judgment on the nuisance claim, concluding that vicarious official immunity applied to the nuisance claim because the alleged nuisance arose from the same immune conduct as the alleged negligence. The Supreme Court affirmed, holding that the City was entitled to vicarious official immunity for both the Homeowners’ claims. View "Kariniemi v. City of Rockford" on Justia Law

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Appellants, LaVonne and Henry Pfeil, were longstanding members of St. Matthew Lutheran Church. St. Matthew’s pastors decided to excommunicate Appellants due to their “slander and gossip” of the church’s leadership and ministry. At special voters’ meeting, the congregation voted to affirm the excommunication decision. LaVonne subsequently brought a lawsuit on behalf of herself and Henry against St. Matthew and its pastors (collectively, Respondents), asserting claims for defamation and negligence. After resolving Henry’s claims on other grounds, the district court dismissed the case with prejudice, concluding that the First Amendment deprived the court of jurisdiction to adjudicate LaVonne’s claims. The court of appeals affirmed. The Supreme Court affirmed, holding that that the First Amendment prohibits holding an organization or individual liable for statements made in the course of a religious disciplinary proceeding when those statements are disseminated only to members of the church congregation or the organization’s membership or hierarchy. View "Pfeil v. St. Matthews Evangelical Lutheran Church" on Justia Law

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The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law

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Respondents, Angela Lennartson and Katie Foss, were involved in separate car accidents and recovered damages in their respective negligence actions. Subsequently, each respondent was awarded no-fault benefits from their insurer, State Farm, in arbitration proceedings under the Minnesota No-Fault Insurance Act (No-Fault Act). State-Farm moved to vacated the arbitration awards, arguing, inter alia, that collateral estoppel barred the no-fault arbitrations. The district court granted State Farm’s motion to vacate in Lennartson’s case and denied it in Foss’s case. The cases were consolidated on appeal. The court of appeals affirmed the decision in favor of Foss and reversed the decision against Lennartson, concluding that neither the No-Fault Act nor collateral estoppel barred the arbitrators’ awards of no-fault benefits to Respondents.The Supreme Court affirmed, holding (1) the No-Fault Act does not bar an insured from recovering no-fault benefits for medical expenses previously recovered in a negligence action; and (2) collateral estoppel does not bar an insured from seeking medical-expense or income-loss benefits in no-fault arbitration recovering damages for the same expenses or losses in a negligence action. View "State Farm Mut. Auto. Ins. Co. v. Lennartson" on Justia Law

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Appellant used Respondent as the general contractor for the construction of a building. When the building began having problems with water intrusion, Appellant brought suit claiming that Respondent acted negligently in its duties as general contractor. The district court granted summary judgment in favor of Respondent, concluding that the action was untimely under the two-year statute of limitations for improvements to real property in Minn. Stat. 541.051(1)(a). The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals correctly found that the plain language of section 541.051(1) does not require that construction be substantially complete to start the running of the statute of limitations; but (2) there remained a genuine issue of material fact as to when Appellant discovered its injury, and therefore, the district court erred in granting summary judgment. Remanded. View "328 Barry Avenue v. Nolan Props. Group, LLC" on Justia Law