Staab v. Diocese of St. Cloud

Summary

The Minnesota Supreme Court interpreted Minn. Stat. § 604.02, subd. 1 (2010), concerning several liability and the allocation of fault among tortfeasors. It held that the statute applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor, limiting the defendant’s collectible liability to its percentage share of fault unless a statutory exception to joint and several liability applies. The court affirmed the court of appeals as modified and remanded for entry of judgment for 50% of the jury’s damages award.

Holdings

1. Section 604.02, subdivision 1, applies whenever multiple tortfeasors cause an indivisible injury, regardless of how many of those tortfeasors are named as parties in the lawsuit. The term "persons" includes parties to the transaction who are not parties to the lawsuit.
2. A defendant that is severally liable but does not fall within one of section 604.02, subdivision 1's exceptions is responsible only for the percentage of the award corresponding to its percentage of fault.
3. The Diocese was liable for only 50 percent of the $224,200.70 jury award, because the jury attributed 50 percent of the fault to the Diocese and 50 percent to a nonparty tortfeasor.

Questions Presented

1. Whether Minn. Stat. § 604.02, subdivision 1, applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor.
2. Whether the Diocese, found 50 percent at fault, was required to pay the entire $224,200.70 damages award or only its proportionate share.
3. Whether the terms "persons," "severally liable," and "jointly and severally liable" in section 604.02 incorporate their common-law meanings and apply based on liability existing when the tort is committed rather than when judgment is entered.

Disposition

affirmed