Justia Injury Law Opinion SummariesArticles Posted in Minnesota Supreme Court
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
DeRosa v. McKenzie
The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court dismissing this defamation action, holding that a corporate officer who did not author a defamatory statement but participated in the publication of the statement may be held personally liable for defamation. Plaintiff brought this action against Defendant, the chief executive officer of Dakota Plains Holdings, Inc., alleging that Defendant authorized, directed, and approved defamatory statements about Plaintiff in a Dakota Plains press release. The district court dismissed the complaint on the pleadings because the complaint did not allege that Defendant made or authored the defamatory statements in the press release. The court of appeals affirmed. The Supreme Court reversed, holding (1) if Plaintiff's allegations are true, Defendant may be held personally liable for his participation; and (2) Plaintiff's complaint sufficiently pleaded a defamation claim to survive a motion to dismiss for failure to state a claim. View "DeRosa v. McKenzie" on Justia Law
Fish v. Ramler Trucking, Inc.
The Supreme Court affirmed the decision of the court of appeals concluding that, by the plain words of Minn. Stat. 604.02, a tortfeasor's liability to an injured employee is not reduced by the employer's fault. At issue was whether the 2003 amendment to Minn. Stat. 604.02, subd. 1 overturned the line of decisions holding that an employer liable to an injured employee under the Workers' Compensation Act and a third party liable in tort to that same employee do not have either joint or several liability. In this case, an employee was injured in the workplace. The employee and his employer settled the workers' compensation claim. The employee brought a negligence against the tortfeasor, which brought a third-party contribution claim against the employer. The jury found that the injury was caused by the employee, the employer, and the tortfeasor. The district court applied section 604.02 to reduce the net damage award to the employee by an amount proportionate to the employer's fault. The court of appeals reversed, concluding that the lower court erred in applying section 604.02 under the circumstances. The Supreme Court affirmed, holding that the tortfeasor's liability to the employee was not reduced by the fault of the employer. View "Fish v. Ramler Trucking, Inc." on Justia Law
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
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