Justia Injury Law Opinion Summaries

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

Respondents, Angela Lennartson and Katie Foss, were involved in separate car accidents and recovered damages in their respective negligence actions. Subsequently, each respondent was awarded no-fault benefits from their insurer, State Farm, in arbitration proceedings under the Minnesota No-Fault Insurance Act (No-Fault Act). State-Farm moved to vacated the arbitration awards, arguing, inter alia, that collateral estoppel barred the no-fault arbitrations. The district court granted State Farm’s motion to vacate in Lennartson’s case and denied it in Foss’s case. The cases were consolidated on appeal. The court of appeals affirmed the decision in favor of Foss and reversed the decision against Lennartson, concluding that neither the No-Fault Act nor collateral estoppel barred the arbitrators’ awards of no-fault benefits to Respondents.The Supreme Court affirmed, holding (1) the No-Fault Act does not bar an insured from recovering no-fault benefits for medical expenses previously recovered in a negligence action; and (2) collateral estoppel does not bar an insured from seeking medical-expense or income-loss benefits in no-fault arbitration recovering damages for the same expenses or losses in a negligence action. View "State Farm Mut. Auto. Ins. Co. v. Lennartson" on Justia Law

Appellant used Respondent as the general contractor for the construction of a building. When the building began having problems with water intrusion, Appellant brought suit claiming that Respondent acted negligently in its duties as general contractor. The district court granted summary judgment in favor of Respondent, concluding that the action was untimely under the two-year statute of limitations for improvements to real property in Minn. Stat. 541.051(1)(a). The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals correctly found that the plain language of section 541.051(1) does not require that construction be substantially complete to start the running of the statute of limitations; but (2) there remained a genuine issue of material fact as to when Appellant discovered its injury, and therefore, the district court erred in granting summary judgment. Remanded. View "328 Barry Avenue v. Nolan Props. Group, LLC" on Justia Law

Sinuon and Lawrence Leiendecker, husband and wife, were involved in litigation with Asian Women United of Minnesota (AWUM), a nonprofit organization, for a decade. In this lawsuit, the fifth suit between the parties,the Leiendeckers sought to recover for injuries allegedly inflicted by AWUM and other defendants through the suits the defendants brought against the Leiendeckers in the past. AWUM moved for dismissal under Minnesota’s anti-SLAPP statutes. The district court denied AWUM’s anti-SLAPP motion, concluding that the allegations in the Leiendeckers’ complaint were sufficient to defeat the motion. The Supreme Court reversed, holding that the anti-SLAPP statutes required the Leiendeckers to produce evidence to defeat the anti-SLAPP motion rather than rely solely on the allegations in their complaint. View "Leiendecker v. Asian Women United of Minn." on Justia Law

Plaintiffs, owners of a dairy farm, sued Wright-Hennepin Cooperative Electric Association for stray voltage that allegedly injured their herd of dairy cows. The jury found that Wright-Hennepin had been negligent, had created a nuisance, and had trespassed and returned a special verdict awarding Plaintiffs $753,200 in damages. Wright-Hennepin moved, post-trial, that the district court issue supplemental findings itemizing the $753,200 judgment. The district court granted the motion. The court of appeals affirmed in part, reversed in part, and remanded for a new trial on the issue of damages, determining that the district court lacked authority to amend the judgment to itemize the jury’s damages award. The Supreme Court affirmed, holding that the district court had no authority, by rule or by inherent power, to amend the judgment to itemize the jury’s damages award. View "Poppler v. Wright Hennepin Coop. Elec. Ass'n" on Justia Law

Plaintiff applied for a job within the Mounds View Police Department, which commenced a background investigation. Mounds View contacted the Minneapolis Police Department, where Plaintiff previously worked, and interviewed Sergeant Janice Callaway, one of Plaintiff’s former supervisors, who allegedly made defamatory statements about Plaintiff. Plaintiff subsequently sued Callaway and the City of Minneapolis for intentional interference with prospective economic advantage and for defamation. The district court granted Defendants’ motion for summary judgment with respect to the intentional interference claim but allowed the defamation claim to proceed. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not err in denying summary judgment on the defamation claim, as absolute privilege did not apply to the allegedly defamatory statements made by Callaway. View "Minke v. City of Minneapolis" on Justia Law