Supreme Court Digest: Oct. 16, 2019

Civil

Damages

Collateral Sources

After her car struck a school bus that failed to yield at an intersection, respondent brought a suit against the bus driver and the owner of the bus, appellants. Respondent was a medical-assistance enrollee, and her medical expenses were covered by two managed-care organizations that contracted with Minnesota’s Prepaid Medical Assistance Plan under Minnesota’s Medicaid program. After a trial, the jury awarded respondent damages, but the District Court deducted from the award the amount of discounts negotiated by respondent’s managed-care organizations. The Court of Appeals reversed, holding that the discounts were excepted from offset because they were “payments made pursuant to the United States Social Security Act,” under Minn. Stat. § 548.251, subd. 1(2).

The Supreme Court held that (1) discounts negotiated by managed-care organizations under Minnesota’s Prepaid Medical Assistance Plan are “payments made pursuant to the United States Social Security Act” and therefore are not deducted from the jury’s damages award under the collateral-source statute; and (2) the Legislature intended to displace the common-law collateral-source rule for medical insurance payments and thus the common law cannot be used to reduce the jury’s damages award. Affirmed.

A18-0121 Getz v. Peace (Court of Appeals)

Municipalities

Referenda

At issue here was whether the District Court erred in directing the City of Saint Paul to put a referendum question, regarding the city’s ordinance that established organized waste collection in the city, on the ballot for the next municipal election. The District Court concluded that doing so would not conflict with state law regarding the process for organized waste collection and would not unconstitutionally impair the city’s contract with the haulers that provide that service. In an order filed on August 22, 2019, the Supreme Court affirmed the District Court with opinion to follow.

The Supreme Court held that (1) a referendum on a Saint Paul ordinance that establishes organized waste collection services does not conflict with the requirements in Minn. Stat. §§ 115A.94–.941 that municipalities ensure that residents have waste collection services including through appropriate local controls, because ordinances that are not subject to the referendum fulfill those requirements and the Legislature intended that municipalities have broad authority in the process for establishing organized waste collection; and (2) a referendum on an ordinance that establishes organized waste collection services in the City does not impair the city’s contract obligations under the Contract Clauses of the United States and Minnesota Constitutions. Affirmed.

A19-0916 Clark v. City of St. Paul (Ramsey County)