Staab v. Diocese of St. Cloud
2013 Minn. App. LEXIS 38
Minn. Ct. App.2013Background
- In 2005, Alice Staab injured when Richard Staab, a nonparty, pushed a wheelchair through a doorway with a five-inch drop at Holy Cross Parish School.
- Alice sued the Diocese of St. Cloud; Richard Staab was not named as a party and no third-party claim was filed.
- The jury found 50% fault to the Diocese and 50% to Richard Staab, awarding $224,200.70 in total damages.
- Initial district court ruling required the Diocese to pay the entire award; this court reversed, and the supreme court affirmed, clarifying § 604.02 applies when a nonparty is apportioned fault.
- On remand, the district court reallocated Richard Staab’s uncollectible share to the Diocese under § 604.02, subd. 2, and entered judgment against the Diocese for the remainder plus costs and interest.
- The district court later amended the judgment and awarded interest from August 7, 2012 (date of reallocation) rather than from the verdict date.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 604.02, subd. 2 permit reallocation to a nonparty tortfeasor? | Staab: yes, not limited to party defendants. | Diocese: no; reallocation requires a party and judgment against them. | Reallocation applies to nonparties; no joint-and-several prerequisite. |
| When does post-verdict interest accrue after reallocation? | Staab: interest from verdict date. | Diocese: interest from reallocation date. | Interest accrues from the date of the reallocation order. |
Key Cases Cited
- Staab v. Diocese of St. Cloud, 813 N.W.2d 68 (Minn. 2012) (confirms broad 'party' meaning includes nonparties for § 604.02 reallocation)
- O’Brien v. Dombeck, 823 N.W.2d 895 (Minn. App. 2012) (amendment to limit joint-and-several liability left subdivision 2 intact)
- Schneider v. Buckman, 433 N.W.2d 98 (Minn. 1988) (limits subdivision 2 when only one defendant liable under pre-2003 rule)
- Hosley v. Pittsburgh-Corning Corp., 383 N.W.2d 293 (Minn. 1986) (allocates equitable shares to nonparty tortfeasors under § 604.02)
- Hosley II, 401 N.W.2d 136 (Minn. App. 1987) (prematurity of uncollectibility findings when co-tortfeasor bankruptcy exists)
- Hurr v. Davis, 155 Minn. 456 (1923) (jurisdiction limits to enforce judgments against nonparties)