Justia Injury Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Maethner v. Someplace Safe, Inc.
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the decision of the district court granting summary judgment to Appellants - Someplace Safe, Inc. an advocacy organization, and Jacquelyn Jorud, Respondent's former wife - in this defamation and negligence action, holding that summary judgment was properly awarded to Someplace Safe on negligence but that the question of damages required a remand. Respondent alleged that Appellants' statements accused him of committing domestic violence. The district court granted summary judgment to Appellants on the defamation claims, concluding that the statements were protected by a qualified privilege, Respondent failed to establish a genuine issue of material face on malice, and Respondent had not shown proof of actual damages. The court of appeals reversed, concluding that Respondent provided sufficient evidence of damages and breach of duty to warrant a trial on his claims. The Supreme Court held (1) Respondent's defamation claim against Jorud must be remanded to determine whether the allegedly defamatory statements involved a matter of public or private concern; and (2) no material fact questions existed about whether Someplace Safe acted with reasonable care before publishing the allegedly defamatory statements. View "Maethner v. Someplace Safe, Inc." on Justia Law
Heilman v. Courtney
The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of judgment on the pleadings to the State on Appellant's claims alleging false imprisonment and negligence, holding that the conditional release imposed under Minn. Stat. 169A.276, subd. 1(d), unambiguously begins when a Challenge Incarceration Program participant enters phase II of the program and begins living in the community. Appellant, a participant in the Challenge Incarceration Program administered by the Department of Corrections, brought this action arguing that the State failed correctly to calculate his conditional-release term and revoked his conditional release improperly after it had already ended. Specifically, Appellant argued that he was "released from prison" within the meaning of section 169A.276, subd. 1(d) when he entered phase II of that program. The district court granted the State's motion for judgment on the pleadings. The court of appeals affirmed. The Supreme Court reversed, holding that the conditional-release term imposed by section 169A.276, subd. 1(d), begins when a participant in the Challenge Incarceration Program begins living in the community. View "Heilman v. Courtney" on Justia Law
Johnson v. Darchuks Fabrication, Inc.
The Supreme Court reversed the conclusion of the Workers' Compensation Court of Appeals that the medical treatment parameters established under the Workers' Compensation Act do not apply when an employer contests its obligation under the Act to pay for an employee's particular medical treatment. Employee sought workers' compensation benefits for a work injury. Employer paid a lump sum and agreed to pay ongoing medical expenses that were reasonably required to cure and relieve Employee's symptoms. Employer paid for Employee's medical treatment until it determined that Employee's current treatment was no longer reasonable or necessary. Employee then filed a workers' compensation medical request seeking payment to cover the cost of his medications. Employer denied the request. A workers' compensation judge ordered Employer to pay for Employee's medications and treatment, holding that the treatment parameters did not apply to Employee's claim. The Workers' Compensation Court of Appeals affirmed. The Supreme Court reversed, holding (1) the ban on applying the treatment parameters in Minnesota Rule 5221.6020, subpart 2, applies only when an employer denies that it has an obligation under the Act to pay compensation for an alleged workplace injury; and (2) the workers' compensation tribunals erred in concluding that the treatment parameters did not apply to Employee's course of treatment. View "Johnson v. Darchuks Fabrication, Inc." on Justia Law
Soderberg v. Anderson
The Supreme Court in this negligence case decided not to extend the doctrine of implied primary assumption of risk, which is a complete bar to tort liability, to recreational skiing and snowboarding, thus affirming the decision of the court of appeals concluding that the district court erred in granting summary judgment to Defendant. Plaintiff, a ski instructor, was struck by Defendant, an adult snowboarder performing an aerial trick, while Plaintiff was teaching a young student in an area marked “slow skiing area.” Plaintiff sued Defendant for negligence. The district court granted summary judgment for Defendant, concluding that under the doctrine of implied primary assumption of risk Defendant owed Plaintiff no duty of care. The court of appeals reversed after assuming that the doctrine of implied primary assumption of risk generally applies to actions between skiers, holding that material fact issues precluded summary judgment. The Supreme Court affirmed on different grounds, holding that the doctrine of implied primary assumption of risk does not extend to recreational downhill skiing and snowboarding. The Court remanded the case. View "Soderberg v. Anderson" on Justia Law
Henson v. Uptown Drink, LLC
The Supreme Court affirmed the judgment of the court of appeals reversing the district court’s grant of summary judgment in favor of Defendant, a Minneapolis bar, on Plaintiffs’ complaint pleading innkeeper-negligence and dram-shop claims, holding that summary judgment on both claims was improper. An off-duty employee of Defendant was fatally injured while helping other bar employees force an aggressive patron out of the bar. Plaintiffs, the decedent’s family, sued Defendant for the death. In granting summary judgment for Defendant, the district court determined (1) as to the innkeeper-negligence claim, the bar owed no duty based on the doctrine of implied primary assumption of risk; and (2) as to the dram-shop claim, the claim failed on the element of proximate cause. The court of appeals reversed. The Supreme Court affirmed, holding (1) the doctrine of implied primary assumption of risk does not apply to the operation and patronage of bars; and (2) there existed a genuine issue of material fact as to whether the aggressive patron’s actions were a proximate cause of the decedent’s fatal injury. View "Henson v. Uptown Drink, LLC" on Justia Law
Fenrich v. The Blake School
The Supreme Court reversed the judgment of the court of appeals affirming the district court’s grant of summary judgment for The Blake School (the school) on Appellant’s negligence action based on a fatal accident caused by a high-school student while he was driving his cross-county teammates and a volunteer coach to an extracurricular athletic competition, holding that summary judgment was not proper under the circumstances of this case. In granting summary judgment for the school, the district court concluded that the school did not owe a duty of care to members of the general public as a matter of law. The court of appeals affirmed on a different ground, concluding that the school’s conduct did not create a foreseeable risk of injury to a foreseeable plaintiff. The Supreme Court reversed, holding (1) the school was subject to the black-letter common-law rule that it may be liable for the negligence of others if its own conduct creates a foreseeable risk of injury to a foreseeable plaintiff; and (2) foreseeability was at least a close call, making summary judgment on the element of duty inappropriate. View "Fenrich v. The Blake School" on Justia Law
Roller-Dick v. CentraCare Health System
The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that Plaintiff’s injury “arose out of” her employment under the “increased-risk” test the Court applied in Dykhoff v. Xcel Energy, 840 N.W.2d 821 (Minn. 2013). Plaintiff, an employee of Relator, fell down a set of stairs as she was leaving work. The workers’ compensation judge held that the injury did not arise out of employment. The WCCA reversed, determining that the compensation judge applied the incorrect test to determine whether the stairs were hazardous and that the correct test was whether the stairs posed an “increased risk” as opposed to a “neutral risk.” Because the stairs alone increased Plaintiff’s risk of injury, the WCCA concluded that her injury arose out of her employment. The Supreme Court affirmed, holding (1) an injury arises out of employment when there is a causal connection between the injury and the employment; and (2) applying that rule, there was a causal connection between Plaintiff’s injury on the stairway and her employment. View "Roller-Dick v. CentraCare Health System" on Justia Law
Hufnagel v. Deer River Health Care Center
The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that the compensation judge failed fully to consider the extent to which each of Respondent’s employers sought to shift liability to the other employer and that it was error to deny Respondent’s motion for fees under Minn. Stat. 176.191(1). In 2015, Respondent filed a workers’ compensation claim for work-related aggravations to a low-back condition resulting from a work-related injury in 2009. Between the 2009 injury and later aggravations sustained in 2014 and 2015, Respondent’s employer and its insurer changed. When Respondent sought benefits for later aggravations sustained in 2014 and 2015, her 2009-employer and her new employer disputed whether the aggravations were a continuation of the 2009 injury or subsequent injuries for which the new employer and its insurer were liable. The compensation judge held the new employer liable for reasonable benefits for the later injuries but denied Respondent’s claim for fees under section 176.191(1). The WCCA reversed the denial of the motion for fees. The Supreme Court affirmed, holding that the efforts by each employer to shift responsibility to the other employer greatly increased the burden on Respondent’s counsel to provide effective representation, and therefore, Respondent was entitled to receive reasonable attorney fees under the statute. View "Hufnagel v. Deer River Health Care Center" on Justia Law
Ouradnik v. Ouradnik
The Supreme Court affirmed the judgment of the court of appeals reversing the district court’s grant of partial summary judgment in favor of Father on Son’s personal injury suit, holding that the Recreational-Use Statute, Minn. Stat. 604A.20-.27, did not apply to the facts of this case. Son was injured after he fell from a deer stand on Father’s property. The district court ruled that Father was entitled to recreational-use immunity, which allowed Son to proceed to trial to seek recovery under the trespasser exception to the statute. Based solely on the trespasser theory, the jury concluded that Son was ninety-five percent negligent. The court of appeals remanded the case for a new trial, holding that because Father did not offer his land for use by the public, the Recreational-Use Statute did not apply. The Supreme Court affirmed, holding that where the usage of Father’s property was limited to immediate family, section 604A.22 did not apply to this case because the land was not offered for public use. View "Ouradnik v. Ouradnik" on Justia Law
Dewitt v. London Road Rental Center, Inc.
At issue was whether an indemnity clause in a rental agreement required the renter to indemnify the rental company for the rental company’s negligence. The Tower Tap & Restaurant entered into an agreement to rent folding picnic tables from London Road Rental Center, Inc. for an event. Plaintiff injured his hip at Tower Tap’s event after one of the rented tables collapsed on him. Plaintiff sued Tower Tap and London Road. London Road filed a cross-claim against Tower Tap, seeking contractual indemnity based on the indemnity clause in the rental agreement. The district court granted summary judgment to London Road, concluding that the clause unequivocally covered liability for London Road’s own negligence. The court of appeals affirmed. The Supreme Court reversed, holding that the indemnity clause did not include express language that clearly and unequivocally showed the parties’ intent to transfer such liability to Tower Tap. View "Dewitt v. London Road Rental Center, Inc." on Justia Law