Ptacek v. Earthsoils, Inc., 844 N.W.2d 535

Earthsoils (McCornack) sold and recommended fertilizer to Láveme and Jeffrey Ptacek for the 2007 corn crop; Ptaceks alleged the fertilizer lacked sufficient nitrogen and caused crop failure.
Ptaceks sued (Dec. 2008) alleging breach of contract, consumer misrepresentation, negligence, and warranty claims; they claimed expected yields (180–200 bu/acre) were less than half because of nitrogen deficiency.
Respondents moved for summary judgment arguing the economic-loss doctrine barred the claims; the district court granted summary judgment only on negligence under the common-law economic-loss doctrine and denied it for other claims.
At trial, the district court admitted Ptaceks’ crop-insurance claim forms (which attributed loss 100% to drought) over Ptaceks’ motion in limine and instructed the jury not to consider insurance payments when awarding damages.
The jury found for respondents on breach, warranty, and misrepresentation claims; Ptaceks’ post-trial motion for a new trial based on admission of the insurance forms was denied.
On appeal the court affirmed the evidentiary ruling but reversed summary judgment on negligence, holding Minn. Stat. § 604.101 fully supplants any common-law economic-loss doctrine for sales-related claims after Aug. 1, 2000, so the district court erred to bar negligence on common-law grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether negligence claim was barred by the economic-loss doctrine	Ptaceks argued negligence is viable against seller; statutory EL doctrine does not bar their negligence claim here	Earthsoils argued the economic-loss doctrine (common-law or statutory) bars tort recovery for purely monetary loss from a sale of goods	Reversed: district court erred to apply common-law economic-loss rule; Minn. Stat. § 604.101 exhaustively states the doctrine and does not bar these negligence claims as applied by the court below
Admissibility of crop-insurance claim forms	Ptaceks argued forms were irrelevant or unfairly prejudicial and should be excluded	Earthsoils argued forms were relevant to causation and inconsistent statements; jury instructed on limited use	Affirmed: trial court did not abuse discretion; forms were relevant to causation, probative value not substantially outweighed by prejudice, and Ptaceks competent as experienced farmers to offer lay causation opinions

Riverview Muir Doran, LLC v. JADT Dev. Grp., LLC, 790 N.W.2d 167 (Minn. 2010) (standard of review for summary judgment)
Wartnick v. Moss & Barnett, 490 N.W.2d 108 (Minn. 1992) (appellate review scope on summary judgment)
Weston v. McWilliams & Assocs., Inc., 716 N.W.2d 684 (Minn. 2006) (statutory interpretation and application reviewed de novo)
Kroning v. State Farm Auto. Ins. Co., 567 N.W.2d 42 (Minn. 1997) (trial court admitted evidence reviewed for abuse of discretion)
State v. Schulz, 691 N.W.2d 474 (Minn. 2005) (definition of unfair prejudice under Rule 403)
Wilson v. Home Gas Co., 125 N.W.2d 725 (Minn. 1963) (insurance evidence may be admissible to prove or rebut issues despite prejudice)
Muehlhauser v. Erickson, 621 N.W.2d 24 (Minn. App. 2000) (competency of lay opinion testimony reviewed for abuse of discretion)