Summary
The Minnesota Supreme Court held that punitive damages may be sought in an action for intentional damage to property even when the only resulting harm is property damage. The court distinguished prior limitations applicable to certain product-liability actions and concluded that Minn. Stat. § 549.20 focuses on deliberate disregard for the rights or safety of others rather than the type of damage. The court reversed and remanded for reconsideration of the plaintiffs' motion to amend their complaint.
Topics
Practice areas
Questions Presented
- Whether punitive damages are available in an action for intentional damage to property when the only damage is to property.
Holdings
- A plaintiff may seek punitive damages in an action for intentional damage to property where the only damage is to property, subject to the limitations and criteria of Minn. Stat. § 549.20.
Key quotations
“A plain reading of section 549.20 indicates that the legislature intended to allow punitive damages when there is clear and convincing evidence that a defendant acted with deliberate disregard for the rights or safety of others regardless of the nature of the resulting damage.” (251)
“Thus, we hold that a plaintiff may seek punitive damages in an action for intentional damage to property where the only damage is to property, subject to the limitations of section 549.20.” (251)
Factual background
The Jensens and Walshes owned adjacent property along a Mississippi River channel, where the Jensens kept a houseboat. In an effort to drive the Jensens away or induce them to remove the houseboat, James Walsh and Timothy Schacher stole an electric meter, cut a telephone line, spray-painted the Jensens' garage, threw eggs at their property, and punctured vehicle tires. The Jensens sought damages for intentional property damage and emotional distress; the property-damage claim was later settled for $5,765, subject to their appeal concerning punitive damages.
Procedural history
The Jensens sued the Walshes and Schacher for intentional property damage and intentional infliction of emotional distress. The district court dismissed the emotional-distress claim on partial summary judgment and denied the motion to amend to add punitive damages. After the parties settled the property-damage claim while reserving appellate rights, the court of appeals affirmed. The Minnesota Supreme Court reversed and remanded for reconsideration of the motion to amend under Minn. Stat. § 549.20.
Remand instructions
The district court must reconsider the Jensens' motion to amend their complaint to include a punitive-damages claim, applying the criteria set forth in Minn. Stat. § 549.20.