Justia Injury Law Opinion Summaries

The Workers’ Compensation Court of Appeals (WCCA) clearly and manifestly erred by rejecting the findings of the compensation judge and overturning the determination that Respondent failed to establish her claim for benefits by a preponderance of the evidence. Respondent filed a claim for workers’ compensation benefits after falling and injuring her shoulder while rushing up a staircase at the workplace of her employer. The compensation judge denied the claim. The WCCA reversed the compensation judge’s decision. The Supreme Court reversed the WCCA’s decision and reinstated the compensation judge’s decision, holding (1) the WCCA impermissibly substituted its own view of the evidence for that of the compensation judge; and (2) the findings of the compensation judge were supported by substantial evidence that a reasonable mind would accept as adequate. View "Kubis v. Community Memorial Hospital Ass’n" on Justia Law

The Workers’ Compensation Court of Appeals (WCCA) was correct in concluding that Respondent’s injury was compensable.Respondent, who was employed by the University of Minnesota, slipped and fell on any icy sidewalk when walking from her workplace to a parking ramp owned and operated by the university. The compensation judge denied Respondent’s claim for workers’ compensation benefits, concluding that Respondent’s injury did not “arise out of” her employment. The WCCA reversed, concluding that Respondent was in the course of her employment when she was injured. The Supreme Court affirmed, holding that Respondent’s injury was compensable because it both arose out of, and was in the course of, her employment. View "Hohlt v. University of Minnesota" on Justia Law

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

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

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

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

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

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

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

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