24 N.W.3d 670
Minn.2025Background
- Lee Scheurer was injured in a 2017 car accident caused by Ann Maland’s negligence.
- Scheurer served a written notice of claim to Maland’s insurer in September 2017 but did not file his lawsuit until November 2020, over three years later.
- A jury awarded Scheurer $292,340 in compensatory damages, but the district court reduced this to $194,631 after subtracting collateral source payments (mainly insurance).
- Dispute arose over when preverdict interest should begin to accrue (date of notice of claim or lawsuit filing) and whether interest should be calculated on the full jury award or the reduced judgment.
- District court sided with the Estate on both issues; the court of appeals affirmed as to accrual but reversed as to calculation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When does preverdict interest begin to accrue if an offer of settlement is served? | Scheurer argued interest should accrue from the date of the notice of claim, even if action filed more than two years later, when a written settlement offer is served. | Estate argued action must be commenced within two years of notice for interest to accrue from notice date, regardless of settlement offer. | Court held two-year commencement requirement applies even if a settlement offer is served; interest accrues from filing date if not met. |
| Is preverdict interest calculated on the jury award or the judgment after collateral source reductions? | Scheurer argued interest should be calculated on the jury’s full verdict, prior to collateral source deduction. | Estate argued it should be calculated on the reduced judgment (after deduction). | Court held interest accrues only on the judgment after deducting collateral source payments. |
Key Cases Cited
- Poehler v. Cincinnati Ins. Co., 899 N.W.2d 135 (Minn. 2017) (addresses statutory interpretation and prejudgment interest)
- State v. Riggs, 865 N.W.2d 679 (Minn. 2015) (rule of statutory construction—harmonizing statute as a whole)
- Lienhard v. State, 431 N.W.2d 861 (Minn. 1988) (purpose and nature of preverdict interest)
- Hodder v. Goodyear Tire & Rubber Co., 426 N.W.2d 826 (Minn. 1988) (interpreting offer-counteroffer provision in preverdict interest statute)
- State v. Hanson, 543 N.W.2d 84 (Minn. 1996) (legislative history as tool in statutory interpretation)
