Justia Injury Law Opinion Summaries

Plaintiff Alice Ann Staab brought suit against Defendant Diocese of St. Cloud for injuries she sustained on premises Defendant owned and operated. A special jury verdict attributed fifty percent of the negligence to the sole defendant and fifty percent of the negligence to a nonparty to the lawsuit. The district court ruled that Minn. Stat. 604.02, subd. 1 does not apply in an action against only one defendant and ordered Defendant to pay the entire damages award. The court of appeals reversed, holding that under the plain language of section 604.02, subdivision 1, Defendant must pay only in proportion to the percentage of fault attributed to Defendant by the jury. The Supreme Court affirmed but under a different analysis, holding (1) section 604.02, subdivision 1, applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor and limits the amount collectible from the defendant to its percentage share of the fault assigned to it by the jury; and (2) consequently, Defendant must pay Plaintiff fifty percent of the jury award, Defendant's share of the fault as determined by the jury.

Employee was injured in a work-related accident in Minnesota and then moved to Wyoming where she received medical treatment. The Wyoming medical providers submitted their charges to Employer's workers' compensation insurer. Relying on Minn. Stat. 176.136, subd. 1b(d), the insurer made payments in the amount provided under the workers' compensation benefit structure in Wyoming. Employee filed a workers' compensation medical request for the unpaid balance, arguing that Minn. Stat. 176.135, subd. 1 was controlling. The workers' compensation judge agreed and found for Employee. The workers' compensation court of appeals reversed. The Supreme Court affirmed, holding (1) Minn. Stat. 176.136, subd. 1b(d) limits a Minnesota employer's workers' compensation liability to an out-of-state medical provider to the amounts provided in the workers' compensation schedule of benefits in the state where the provider is located; and (2) section 16.136, subd. 1b(d) was not unconstitutional as applied.

A collision between an automobile and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. Plaintiffs, the representatives of the decedents' estates, brought wrongful death claims against BNSF, alleging negligence in the maintenance of warning signals and failure to comply with several state and federal regulations. During trial, the district court instructed the jury, without objection from BNSF, to apply a common-law or "reasonable person" standard of care. The jury returned a verdict in Plaintiffs' favor. A divided court of appeals reversed and remanded the matter for a new trial, concluding that the district court's jury instruction and special verdict form using a common-law duty of care constituted plain error that substantially affected BNSF's rights and the fairness and integrity of the proceedings. The Supreme Court (1) reversed the court of appeals' grant of a new trial on the ground of error in the instructions and verdict form, holding that any error did not affect the fairness and integrity of the proceedings; and (2) affirmed the district court's denial of BNSF's motion for a new trial.

Respondent Jill Engquist, as parent and natural guardian of minor Amber Engquist, sued Appellants, Steven and Christina Loyas, for injuries Amber sustained as a result of a dog bite that occurred at Appellants' residence. The district court entered judgment in favor of Appellants after finding that Amber provoked the dog to bite her. The court of appeals reversed on the ground that the jury instruction given by the district court misstated the meaning of provocation under Minn. Stat. 347.22. The Supreme Court affirmed, holding that because the jury could have found provocation without any consideration of the victim's knowledge of the danger, the jury instructions materially misstated the law and prejudiced Respondent. Remanded for a new trial.

Appellant Elaine Wesely filed a dental malpractice action, alleging that she received negligent care from dentist A. David Flor. To satisfy the statutory requirement of expert disclosure, Wesely submitted an affidavit disclosing the opinions of a doctor of internal medicine, not a dentist. After Flor moved to dismiss the claim, asserting the affidavit was deficient because the internist was not qualified to be an expert in the action, Wesely's counsel submitted a second affidavit identifying a dentist-expert and disclosing his opinions. The district court granted Flor's motion to dismiss, concluding that the second affidavit did not amend the original affidavit. The court of appeals affirmed. The Supreme Court reversed, holding that the second affidavit was an amended affidavit that was capable of correcting the alleged deficiencies of the first affidavit. Remanded.

Appellants were trustees of eight family trusts. After stock of closely-held corporation belonging to the trusts was fractionalized in a reverse stock split and Appellants were forced to accept cash in exchange for their shares, Appellants brought suit against the corporation. The district court dismissed all of Appellants' claims. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the valuation of the stock was not the product of common law fraud; (2) Minn. Stat. 302A.471 does not provide for dissenters' rights in the event of a reverse stock split; (3) Appellants were not entitled to equitable relief under Minn. Stat. 302A.751 because the corporation did not frustrate Appellants' reasonable expectations as shareholders; (4) merely conducting an involuntary redemption of Appellants' stock at a fair price, without more, did not constitute a breach of fiduciary duty; and (5) the district court did not err in determining the fair value of Appellants' stock when it adopted a valuation that relied in part on asset value.

Gregory Latterell, on behalf of his stepson Jared Boom's estate, sued Progressive Northern Insurance and AIG Insurance to recover underinsured motorist (UIM) benefits following Boom's death from a motor vehicle accident. Progressive, the insurer of Boom's vehicle, denied Latterell's claim for UIM benefits because of a business-use exclusion in Boom's insurance policy. AIG, Lattrell's insurer, also denied Latterell's claim. Latterell sued, and the district court granted summary judgment to Progressive and AIG. The court of appeals affirmed, holding (1) the business-use exclusion in the Progressive policy was enforceable under the Minnesota No-Fault Automobile Insurance Act and unambiguously excluded UIM coverage under the specific circumstances of this case, and (2) Latterell could not recover UIM benefits under the AIG policy. The Supreme Court reversed the denial of Latterell's summary judgment as to Progressive, holding that Progressive's business-use exclusion was unenforceable under the No-Fault Act. Remanded with instructions to enter judgment in favor of Latterell against Progressive.

After suffering a work-related injury, Employee underwent surgery at a hospital owned by HealthEast Care System. The injury required surgical implantation of a spinal cord stimulator. Employer's worker's compensation insurance provider, State Auto Insurance, paid part but not all of the surgical expenses, asserting (1) the withheld portion of the expenses was attributable to a price markup added by HealthEast to the price paid by HealthEast for the implant hardware used in Employee's surgery, and (2) the manufacturer of the implant hardware should be required to charge directly for the implant hardware. The compensation judge found that Employer and State Auto were liable for the unpaid balance. The Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding (1) HealthEast could charge for the implant hardware because when more than one health care provider is responsible for the creation of a service, article, or supply, the provider that provides the service, article, or supply in its final form is entitled to charge for it; and (2) a compensation judge does not have the authority to determine a reasonable value of a treatment, service, or supply that is lower than eighty-five percent of the provider's usual or customary charge.

David Miller purchased a home owned by respondents Linda Lankow and Jim Betz. The home had previously been extensively remediated because of moisture intrusion damage. Respondents Donnelly Brothers and Total Service Company and defendant Diversified Contractors, Inc. did the remediation work. After discovering and notifying respondents and defendants of additional moisture intrusion damage, buyer began to repair the home. Buyer then commenced an action against respondents and defendant to recover damages. The district court excluded buyer's expert witness evidence as a sanction for the spoliation of evidence that resulted from buyer starting to make repairs to his home. The court then granted respondents' summary judgment motion on the basis that buyer could not make a prima facie case without the expert evidence. The court of appeals affirmed. The Supreme Court reversed, holding that the duty of a custodial party to preserve evidence may be discharged when the custodial party has a legitimate need to destroy the evidence and gives the noncustodial party notice sufficient to enable the noncustodial party to protect itself against the loss of the evidence.

Appellant Michelle Kern was involved in an accident with Cody Janson, whose vehicle was owned by Jessica Gerwing. A year later Kern was involved in an accident with Jennifer Torborg, whose vehicle was owned by James Torborg. Kern sought to recover property damages from the Torborgs in conciliation court, and the conciliation court entered a judgment against James Torborg. Kern and her husband then sued Janson, Gerwing, and the Torborgs in district court, claiming they were jointly and severally liable for Kern's personal injuries. The Torborgs moved for summary judgment, citing the doctrine of res judicata. Kern then moved to vacate the conciliation court judgment. The district court granted Kern's motion, and accordingly, denied the Torborgs' motion for summary judgment. The court of appeals reversed and remanded for entry of summary judgment in favor of the Torborgs because Kern consulted with an attorney before initiating the conciliation court action. On review, the Supreme Court reversed the judgment of the appellate court, holding that consultation with an attorney before initiating a conciliation court action does not automatically preclude vacation of the conciliation court judgment. Remanded.