Alice Ann Staab v. Diocese of St. Cloud
2014 Minn. LEXIS 457
Minn.2014Background
- Staab sued the Diocese of St. Cloud over a fall injury at Holy Cross Parish School caused by a five-inch drop-off, with Staab’s husband (Richard) not named as a party.
- Jury found 50% fault to the Diocese and 50% to Richard Staab; total compensatory damages were $224,200.70.
- District court entered judgment against the Diocese for the full amount, applying former joint-and-several liability rules under § 604.02, subd. 1, because only one defendant was named.
- On remand, Staab sought reallocation of Richard Staab’s equitable share under § 604.02, subd. 2; district court treated Richard’s share as uncollectible and reallocated to the Diocese.
- Court of Appeals affirmed reallocation; the Diocese petitioned for review asserting § 604.02, subd. 2, cannot apply to severally liable parties and that the issue involves interpretation of subdivision 2 with subdivision 1.
- This Court holds that severally liable parties cannot be required to contribute more than their equitable share under § 604.02, subd. 2, and reverses/remands to enter judgment consistent with this holding; the second issue about whether damages must be reduced to a judgment is not reached.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 604.02, subd. 2 applies to severally liable parties | Staab: subdivision 2 applies to all parties, including severally liable. | Diocese: subdivision 2 does not apply to severally liable parties under subdivision 1. | Ambiguous; severally liable party cannot be reallocated under subd. 2. |
| Whether damages must be reduced to a judgment before reallocation under § 604.02, subd. 2 | Staab: reassignment follows from uncollectible portion; no requirement that damages be reduced to a final judgment. | Diocese: reduction-to-judgment is required before reallocation. | Not reached; Court did not decide this due to ruling on first issue. |
Key Cases Cited
- Staab v. Diocese of St. Cloud (Staab I), 813 N.W.2d 68 (Minn.2012) (established that severally liable share is the fault-based proportional share and that reallocation may be limited by later amendments)
- Staab v. Diocese of St. Cloud (Staab II), 813 N.W.2d 68 (Minn.2012) (defined ‘party’ for subd. 2 and held Staab’s 50% share to be non-recoverable from the non-party ‘Richard’ in Staab II context)
- Staab v. Diocese of St. Cloud (Staab III/Staab IV context), 830 N.W.2d 40 (Minn.App.2013) (court of appeals applying plain-text interpretation of subd. 2; subsequent reversal in Staab IV (discussion in dissent))
- O’Brien v. Dombeck, 823 N.W.2d 895 (Minn.App.2012) (illustrates plain-text application of subd. 2 post Staab II)
- State v. Leathers, 799 N.W.2d 606 (Minn.2011) (canons of statutory construction informing ambiguity analysis)