925 N.W.2d 642
Minn. Ct. App.2019Background
- Three Canadian Pacific railroad employees were injured when locomotive seats collapsed; each sued Canadian Pacific under FELA and LIA-based theories.
- Canadian Pacific filed third-party contribution/indemnity claims against seat manufacturer Knoedler, alleging violation of the LIA and federal regulations.
- Canadian Pacific settled with the three employees for a combined $2,464,446.40; the FELA claims were dismissed consistent with those settlements.
- A jury found both Knoedler and Canadian Pacific violated the LIA, proximately caused the injuries, and allocated fault 50/50; judgment for Canadian Pacific equaled half the settlements.
- The district court awarded prejudgment interest under Minn. Stat. § 549.09, subd. 1(b), computed from the date Canadian Pacific commenced its consolidated third-party action; Knoedler appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal law (LIA) preempts Canadian Pacific's state-law contribution/indemnity claims | Engvall controls: state common-law claims for contribution/indemnity premised on violation of the LIA are not preempted | LIA (and Kurns/Napier) preempt state common-law claims about locomotive equipment, so third-party claims should be dismissed | Affirmed denial of summary judgment; Engvall remains binding — LIA does not preempt employer's contribution/indemnity claims premised on LIA violations |
| Whether Canadian Pacific may recover prejudgment interest on its contribution judgment under Minn. Stat. § 549.09, subd. 1(b) | Contribution claim is a state common-law claim; prejudgment interest is allowed on state judgments, so recovery is permitted | Because contribution ultimately seeks FELA-related damages (for which prejudgment interest is not allowed), federal law should bar interest | Canadian Pacific is entitled to prejudgment interest; contribution claim is state-law and not governed by FELA's federal rule barring prejudgment interest |
| Proper accrual date for prejudgment interest on contribution damages | Interest should run from the date the contribution damages were "incurred" — i.e., dates Canadian Pacific settled with each employee | District court correctly started interest at commencement of third-party action (or Knoedler's notice of settlements) | Reversed on calculation: contribution damages are "special damages," so interest accrues from the dates those damages were incurred (the settlement dates), not from suit commencement |
Key Cases Cited
- Napier v. Atlantic Coast Line R.R. Co., 272 U.S. 605 (preemption of state regulation of locomotive design and equipment)
- Kurns v. R.R. Friction Prods. Corp., 565 U.S. 625 (state common-law duties that impose standards for locomotive equipment are preempted)
- Engvall v. Soo Line R.R. Co., 632 N.W.2d 560 (Minn. 2001) (state common-law contribution/indemnity claims premised on LIA violations are not preempted)
- Monessen Sw. Ry. Co. v. Morgan, 486 U.S. 330 (FELA is federal substantive law; damages under FELA are governed by federal law)
- Kinworthy v. Soo Line R. Co., 860 N.W.2d 355 (Minn. 2015) (prejudgment interest under Minn. Stat. § 549.09 is not recoverable in a FELA action)
- Delaware & Hudson Ry. Co. v. Knoedler Mfrs., Inc., 781 F.3d 656 (3d Cir. 2015) (distinguishing claims enforcing federal standards from claims imposing state standards; enforcement of federal standard does not defeat uniformity)