Swenson v. Waseca Mutual Insurance Co.

Court of Appeals of Minnesota
653 N.W.2d 794, 2002 Minn. App. LEXIS 1334, 2002 WL 31749144 (2002)

ELI5:

Rule of Law:

Minnesota’s Good Samaritan law grants immunity from liability for ordinary negligence to a layperson who renders assistance during transit from the scene of an emergency, which includes the act of transporting an injured person to a medical facility, even if the route is briefly indirect.

Facts:

Kelly Swenson, 13, suffered an apparent dislocated knee when her snowmobile crashed into a drainage culvert.
A passing motorist, Lillian Tiegs, stopped to assist Swenson and her companions.
After being unable to get a cell phone signal to call for help, Tiegs offered to drive Swenson to a hospital in her van.
The group planned for Tiegs to first make a brief stop, less than a quarter-mile away at her residence, to allow Swenson's companions to park their snowmobiles.
As Tiegs attempted to make a U-turn from the highway shoulder, her van was struck by a speeding tractor-trailer.
Kelly Swenson died as a result of the injuries she sustained in the collision.

Procedural Posture:

The Swenson family filed a wrongful-death action against Lillian Tiegs and the driver of the tractor-trailer in the district court (trial court).
The Swensons settled their claim against the tractor-trailer driver.
The Swensons then brought an underinsured-motorist claim against Waseca Mutual Insurance Company, Tiegs's insurer.
Waseca Mutual moved for summary judgment, arguing Tiegs was immune from liability under Minnesota’s Good Samaritan law.
The district court granted summary judgment for Waseca Mutual.
The appellant (representing the Swenson family's interests) appealed the district court's grant of summary judgment to the Minnesota Court of Appeals.

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Issue:

Does Minnesota’s Good Samaritan law, Minn. Stat. § 604A.01, subd. 2, provide immunity from liability to a layperson who, while transporting an injured person from an accident scene, negligently causes a fatal car crash, even when the transport involves a brief, indirect route to the hospital?

Opinions:

Majority - G. Barry Anderson

Yes. Minnesota’s Good Samaritan law provides immunity from a negligence claim where a layperson attempts to transport an injured person from the scene of an accident to a health-care facility. The court reasoned that the statutory phrase 'during transit' must be interpreted to include the act of transportation itself. To hold otherwise would undermine the legislative intent of encouraging laypersons to assist those in peril, as it would discourage an entire class of responses to emergencies. The court further held that a roadside personal injury accident is the 'epitome of an emergency' and that the law's protection is not negated by a minor delay or an indirect route to the hospital. The statute does not require the victim's injuries to be life-threatening for an emergency to exist; rather, an emergency is any situation that calls for 'immediate action.'

Analysis:

This decision significantly broadens the scope of immunity provided by Minnesota's Good Samaritan statute by explicitly including the act of transportation as a protected form of 'assistance.' It clarifies that rescuers are shielded not just from claims arising from medical aid, but also from their own ordinary negligence while driving. By adopting a broad definition of 'emergency' that does not require a life-threatening injury, the court lowers the threshold for statutory protection, which will likely encourage more bystanders to intervene. This precedent solidifies protection for rescuers but also limits the legal recourse for victims who are further harmed by a rescuer's ordinary negligence during a transport attempt.

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