Dennis E. Kinworthy v. Soo Line Railroad Company, d/b/a CP Rail System

Summary

The Minnesota Supreme Court held that federal substantive law governs the recoverability of prejudgment interest in a state-court action under the Federal Employers’ Liability Act. Applying Monessen Southwest Railway v. Morgan and related precedent, the court concluded that a successful FELA plaintiff is not entitled to post-verdict, prejudgment interest under Minnesota Statutes section 549.09. The court affirmed the denial of Dennis Kinworthy’s request for interest on his $340,000 jury verdict.

Holdings

1. The recoverability of prejudgment interest in a FELA action brought in state court is governed by federal substantive law, not by the state's characterization of its interest statute as procedural.
2. A successful plaintiff in a FELA action brought in Minnesota state court is not entitled to post-verdict, prejudgment interest under Minn. Stat. § 549.09, subd. 1(a), because federal law does not authorize prejudgment interest in FELA actions.

Questions Presented

1. Whether federal or Minnesota law governs the recoverability of post-verdict, prejudgment interest in a FELA action brought in Minnesota state court.
2. Whether Minn. Stat. § 549.09, subd. 1(a), entitles a successful FELA plaintiff to interest accruing from the jury verdict until entry of judgment.

Disposition

affirmed