Tiedeman ex rel. Tiedeman v. Morgan
1989 Minn. App. LEXIS 55, 435 N.W.2d 86 (1989)
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Rule of Law:
The immunity from liability provided by a Good Samaritan statute does not apply to individuals who have a pre-existing common law duty to provide reasonable care to a person in their charge or control, such as a social host's duty to an invited guest.
Facts:
- Scott Tiedeman, age 17, was a social guest at the home of his girlfriend, Nickole Morgan.
- The Morgans were aware that Tiedeman had a pre-existing heart condition and had undergone heart surgery.
- At approximately 10:26 p.m., after Tiedeman became ill, Nickole Morgan made a 911 call for assistance.
- Robert Morgan, Nickole's father, cancelled the 911 call after Tiedeman allegedly said he was 'fine.'
- Around 10:50 p.m., Tiedeman's condition severely worsened, appearing pale, cool, and clammy.
- After debating how to get him to the hospital, the Morgans summoned an ambulance at approximately 10:58 p.m., shortly after observing he had stopped breathing.
- Tiedeman was found to have no pulse or respiration by ambulance attendants and suffered severe, permanent brain damage due to a prolonged lack of oxygen.
Procedural Posture:
- Scott Tiedeman initiated a negligence action against the Morgans in a Minnesota state trial court.
- The Morgans moved for summary judgment, arguing they were immune from liability under the state's Good Samaritan statute.
- The trial court granted summary judgment in favor of the Morgans, finding that they were entitled to statutory immunity.
- Tiedeman, as appellant, appealed the trial court's grant of summary judgment to the Minnesota Court of Appeals.
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Issue:
Does Minnesota's Good Samaritan statute, which grants immunity to those who render emergency care, relieve a social host of liability for failing to provide reasonable assistance to an ill guest on their premises?
Opinions:
Majority - Crippen, J.
No. Minnesota's Good Samaritan statute does not relieve a social host of liability because the statute's immunity provision applies to voluntary assistance rendered by those with no pre-existing duty, not to those who already have a common law duty of care. The court reasoned that the common law has long recognized a special duty of care for those who are in control of circumstances affecting another, such as a landowner to an invitee, as established in Depue v. Flateau. This pre-existing duty is distinct from the conduct the Good Samaritan statute aims to encourage, which is assistance from volunteers who have no special relationship with the person in distress. The court concluded that the statute was intended to induce action from those who would otherwise have no legal obligation to help, not to diminish or eliminate established common law duties of care.
Analysis:
This decision significantly clarifies the scope of Good Samaritan immunity by distinguishing it from pre-existing common law duties. It establishes that such statutes cannot be used as a shield by individuals, like social hosts, who already owe a duty of reasonable care to persons under their control or on their premises. This reinforces the vitality of common law principles regarding special relationships and prevents the statute from being interpreted in a way that would weaken the protections afforded to guests and invitees. The case serves as a crucial precedent for future negligence claims where a defendant with a pre-existing duty attempts to claim statutory immunity intended for volunteers.
