Kaiser v. Memorial Blood Center of Minneapolis, Inc.
1992 Minn. LEXIS 207, 486 N.W.2d 762, 1992 WL 171588 (1992)
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Rule of Law:
The general six-year statute of limitations for negligence, rather than the two-year statute for medical malpractice, applies to actions against blood banks for negligence in their donor selection and blood screening policies because these are administrative functions not requiring a professional medical license.
Facts:
- On November 7, 1984, Patty Kaiser underwent a tubal ligation surgery.
- The following day, Kaiser received a transfusion of two units of packed red blood cells at Fairview Southdale Hospital.
- The blood components were collected by the American National Red Cross (Red Cross) and provided to Memorial Blood Center of Minneapolis (Memorial) under a sharing agreement.
- One of the two blood donors was later discovered to be infected with the human immunodeficiency virus (HIV).
- Memorial sold the blood to the hospital for Kaiser's transfusion.
- In the spring of 1987, after viewing a television program about AIDS, Kaiser had her blood tested for HIV.
- On April 7, 1987, Kaiser learned that her blood had tested positive for HIV.
- Both Red Cross and Memorial employed licensed physicians and other medical personnel to establish and carry out their blood screening and collection policies.
Procedural Posture:
- Patty and James Kaiser filed a lawsuit against Memorial Blood Center of Minneapolis and the American National Red Cross in Hennepin County District Court (a state trial court).
- The Red Cross removed the case to the U.S. District Court for the District of Minnesota (a federal trial court).
- The defendants moved for summary judgment, arguing the claim was barred by Minnesota's two-year statute of limitations for medical malpractice.
- The U.S. District Court granted the defendants' motions for summary judgment, dismissing the case.
- The Kaisers (appellants) appealed the decision to the U.S. Court of Appeals for the Eighth Circuit (a federal intermediate appellate court).
- The Eighth Circuit affirmed the lower court on jurisdictional grounds but certified two questions of state law regarding the applicable statute of limitations to the Minnesota Supreme Court.
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Issue:
Does the two-year statute of limitations for medical malpractice apply to actions against blood banks for negligence in their blood screening and donor selection policies?
Opinions:
Majority - Wahl, Justice.
No. The six-year statute of limitations for general negligence applies to actions alleging negligence on the part of blood banks in their screening of blood and selection of donors. The court reasoned that the two-year medical malpractice statute, Minn.Stat. § 541.07(1), applies only to a specific list of defendants, which does not explicitly include blood banks. The court rejected the argument that blood banks qualify as 'other health care professionals' because that term, as defined by statute, refers to licensed individuals, not corporate entities. Furthermore, under the canon of ejusdem generis, blood banks are not similar to the listed institutions like 'hospitals, sanitariums, and nursing homes,' which are primarily in-patient, comprehensive care facilities. The court also held that vicarious liability for the acts of physician employees does not trigger the two-year statute in this case. The shorter statute applies only to acts of 'malpractice,' which are defined as professional services requiring a license. The plaintiffs' claims concerned the administrative and policy-making functions of the blood banks—such as setting standards for donor selection and screening—which do not legally require a physician's license to perform. Therefore, the claim is for common law corporate negligence, which is governed by the general six-year statute of limitations.
Analysis:
This decision establishes a critical distinction between medical malpractice and ordinary corporate negligence within healthcare-related entities. It clarifies that an organization's liability is not automatically categorized as malpractice simply because it operates in the medical field or employs licensed professionals. The nature of the specific negligent act is determinative; if the act is administrative or policy-related and does not require a professional license, it constitutes ordinary negligence. This prevents the broad application of shorter malpractice statutes of limitations to systemic or policy-level failures, thereby preserving a longer period for plaintiffs to bring such claims. The ruling forces a functional analysis of the alleged negligence rather than a status-based analysis of the defendant.
