Defendant's Attorney: Kay Nord Hunt, John R. Crawford, Michelle K. Kuhl

Description: Mankato, Minnesota personal injury lawyer represented the Plaintiff on a wrongful death claim.

Following a one-vehicle accident that happened at work and resulted in the death of the vehicle's passenger, that person's next of kin brought a wrongful-death action against the driver and the driver's parents who owned the vehicle. The district court determined that the driver was immune from liability under a provision of the Minnesota Workers' Compensation Act (WCA) that provides that, in most circumstances, a coemployee working for the same employer is not liable to another employee for work-related injuries. Minn. Stat. § 176.061, subd. 5(e) (2022).[1] The issue in this case is whether, despite the immunity of the driver, the vehicle owners can still be held vicariously liable for the driver's conduct under the Minnesota Safety Responsibility Act (SRA), Minn. Stat. § 169.09, subd. 5a (2022), which provides that a vehicle driver is the deemed agent of the vehicle owner if the driver operates the vehicle with the owner's consent and gets into an accident.

* * *

The Safety Responsibility Act establishes a principal-agent relationship between the owner of a vehicle and the vehicle's driver. Minn. Stat. § 169.09, subd. 5a. The SRA was first codified in 1933, and its language has remained largely unchanged since then. See 1933 Minn. Laws ch. 351, § 4; 3 Mason's Minn. Stat. 1934 Supp. § 2720-104. The SRA provides that "[w]henever any motor vehicle shall be operated within this state, by any person other than the owner, with the consent of the owner, express or implied, the operator thereof shall in case of accident, be deemed the agent of the owner of such motor vehicle in the operation thereof." Minn. Stat. § 169.09, subd. 5a.

* * *

Legal issue Can vehicle owners be held vicariously liable under the Minnesota Safety Responsibility Act if the vehicle driver is immune from liability as a coemployee under the Minnesota Workers' Compensation Act?

Outcome: Reversed and remanded.

Plaintiff's Experts:

Defendant's Experts:

Comments: