Staab v. Diocese of St. Cloud
813 N.W.2d 68
| Minn. | 2012Background
- Staab sued the Diocese of St. Cloud for injuries from a wheel-chair incident at Holy Cross Parish School.
- Jury attributed 50% fault to the Diocese and 50% to Richard Staab, a nonparty to the suit.
- Damages awarded were $224,200.70 plus costs.
- District court held § 604.02, subd. 1, does not apply in a single-defendant action and required the Diocese pay the full amount.
- Court of appeals reversed, holding the Diocese liable only for its 50% share; the case proceeded for Supreme Court review.
- The issue is how Minn. Stat. § 604.02, subd. 1, should be applied when a sole defendant and a nonparty share fault and there is an award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effect of § 604.02, subd. 1, when only one defendant is liable | Staab contends the statute applies to limit the defendant's share to its fault percentage | Diocese argues the statute does not apply to single-defendant cases and the Diocese bears the full award | The statute applies; defendant pays 50% of the award. |
| Timing of liability under § 604.02, when two or more are severally liable | Allocation is determined at the time of the tort | Liability is determined at judgment | Liability is determined at the time of the tort for § 604.02 purposes. |
| Meaning of 'persons' and 'parties' under § 604.02, subd. 1 | 'Persons' includes nonparties to the lawsuit | 'Persons' limited to parties to the lawsuit | 'Persons' includes all parties to the tort, including nonparties. |
| Impact of 2003 amendments on single-defendant cases | Amendments reflect broader application to all severally liable parties | Amendments narrowed joint and several liability to four exceptions | Amendments do not override the single-defendant context; statute applies to all severally liable scenarios when multiple parties exist |
Key Cases Cited
- Flaherty v. Northern Pac. Ry. Co., 39 Minn. 328 (Minn. 1888) (joint and several liability for indivisible injuries; liability created at tort moment)
- Schneider v. Buckman, 433 N.W.2d 98 (Minn. 1988) (reallocation not implicated when only one defendant can be entered against)
- Imlay v. City of Lake Crystal, 453 N.W.2d 326 (Minn. 1990) (questions applicability of joint and several liability when plaintiff sues a single defendant)
- Hosley v. Armstrong Cork Co., 383 N.W.2d 289 (Minn. 1986) (defines 'party' in subdivision 2 to include all parties to the transaction)