Schroeder v. Western National Mutual Insurance Co., 865 N.W.2d 66

Carmen Schroeder suffered a serious spinal injury in a 2012 auto accident and was totally disabled for several months, living alone and unable to perform household tasks.
Schroeder did not hire replacement services and received no volunteer help from family or others during her disability.
She claimed replacement service loss benefits under Minn. Stat. § 65B.44, subd. 5, seeking the reasonable value of household services she normally performed ($3,400 claim).
Western National denied payment, arguing benefits require actual replacement of services or an independent showing of economic detriment.
An arbitrator awarded Schroeder the claim; the district court and court of appeals affirmed. The Supreme Court addressed whether replacement of services is a prerequisite to recovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether replacement service loss requires that household services actually be replaced	Schroeder: If she is primarily responsible for household care, she may recover the reasonable value of those services without purchasing replacements	Western National: “Replacement” means services must have been replaced or expenses actually incurred; benefits require economic detriment separate from meeting statutory category	Court: No replacement required for persons with primary household responsibility; satisfying § 65B.44(5) suffices to show economic loss
Whether an independent showing of economic detriment is required in addition to meeting a § 65B.44 category	Schroeder: Satisfying a statutory category (replacement services loss) is itself the economic loss required by the No‑Fault Act	Western National: Plaintiff must separately prove economic detriment beyond qualifying under a statutory category	Court: Rejected — proving a statutory category equals proving “loss” (economic detriment) under the Act

Rindahl v. Nat’l Farmers Union Ins. Cos., 373 N.W.2d 294 (Minn. 1985) (holds persons primarily responsible for household care may recover reasonable value of their services without incurring replacement expenses)
Nadeau v. Austin Mut. Ins. Co., 350 N.W.2d 368 (Minn. 1984) (interprets first clause of § 65B.44(5) as requiring actual expenditures for substitute services)
Johnson v. Am. Family Mut. Ins. Co., 426 N.W.2d 419 (Minn. 1988) (arbitrators limited on legal interpretation in automobile reparation context)
W. Bend Mut. Ins. Co. v. Allstate Ins. Co., 776 N.W.2d 693 (Minn. 2009) (statutory interpretation reviewed de novo)
Axelberg v. Comm’r of Pub. Safety, 848 N.W.2d 206 (Minn. 2014) (courts should not rewrite statutes on policy grounds; Legislature must revise statute if policy change desired)