Justia Injury Law Opinion SummariesArticles Posted in Minnesota Supreme Court
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
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