860 N.W.2d 355
Minn.2015Background
- Plaintiff Dennis Kinworthy, a railroad conductor, sued Soo Line under FELA (and LIA) in Minnesota state court for injuries sustained in 2009; a jury returned a $340,000 verdict for Kinworthy.
- Kinworthy sought post‑verdict interest from the verdict date until judgment entry (~90‑day gap) under Minn. Stat. § 549.09, subd. 1(a).
- District court denied the motion, concluding prejudgment interest is unavailable in FELA cases under U.S. Supreme Court precedent; the court of appeals affirmed.
- The central legal question was whether post‑verdict, pre‑judgment interest is procedural (governed by state law) or substantive (governed by federal law) for FELA claims brought in state court.
- The Minnesota Supreme Court reviewed de novo and held federal substantive law (Monessen/Kaiser) controls, barring any prejudgment interest (pre‑ or post‑verdict) in state‑court FELA actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether post‑verdict interest (verdict date to judgment entry) is recoverable in a state‑court FELA action | Kinworthy: § 549.09 is a procedural/state rule entitling plaintiff to post‑verdict interest | Soo Line: Monessen bars prejudgment interest in FELA actions; federal substantive law controls | Held: Not recoverable—prejudgment interest (pre‑ and post‑verdict) is governed by federal law and is unavailable in FELA suits |
| Whether Monessen's prohibition on prejudgment interest applies to post‑verdict interest as well as pre‑verdict interest | Kinworthy: Monessen addressed only pre‑verdict interest; post‑verdict interest serves a different purpose and should be allowed | Soo Line: Monessen used the broad term “prejudgment interest” and federal law does not authorize any prejudgment interest in FELA cases | Held: Monessen construed broadly; post‑verdict interest is prejudgment interest and barred |
| Whether state procedural rules may create a variance from federal practice and lead to nonuniform FELA liability | Kinworthy: Allowing § 549.09 post‑verdict interest promotes parity with federal practice | Soo Line: Allowing state rule would undermine FELA uniformity and substitute state law for federal substantive law | Held: Uniformity favors applying federal substantive rule; state rule cannot override Monessen |
| Whether courts can avoid the interest gap via immediate entry of judgment | Kinworthy: argued practical disparity with federal court timing harms plaintiffs | Soo Line: not directly disputed—court noted state court discretion | Held: Concurring justice suggested courts may order immediate entry under rule exception; but that is a judicial practice point, not a change to substantive law |
Key Cases Cited
- Monessen Southwestern Ry. Co. v. Morgan, 486 U.S. 330 (1988) (state courts may not award prejudgment interest in FELA actions; prejudgment interest is a federal substantive matter)
- Kaiser Aluminum & Chemical Corp. v. Bonjorno, 494 U.S. 827 (1990) (post‑judgment interest under 28 U.S.C. § 1961 runs from entry of judgment, confirming interest prior to judgment is prejudgment interest)
- Dice v. Akron, Canton & Youngstown R.R., 342 U.S. 359 (1952) (FELA brings substantive matters under federal law even in state court to ensure uniformity)
- Brown v. Western Ry. of Ala., 338 U.S. 294 (1949) (distinguishing procedural/state rules from federal substantive rules in federal causes of action tried in state courts)
- Lienhard v. State, 431 N.W.2d 861 (Minn. 1988) (Minnesota characterization of post‑verdict interest as compensation for loss of use of money—state rule invoked by plaintiff but displaced here by federal law)