Staab v. Diocese of St. CloudAnnotate this Case
Alice Staab sued Diocese of St. Cloud for negligence. The jury awarded compensatory damages of $224,200, attributing fifty percent of the negligence that caused Alice’s injuries to the Diocese and fifty percent to Alice’s husband, Richard. Richard was not named as a party in the lawsuit. The district court entered judgment for $224,200 against the Diocese, concluding that Minn. Stat. 604.02(1), which limits liability for a severally liable person, does not apply when only one defendant is named in a lawsuit. The Supreme Court reversed, holding that section 604.02(1) applies when a jury apportions fault between a sole defendant and a nonparty tortfeasor. On remand, the district court entered judgment against the Diocese for the entire damages award, concluding that an uncollectible share of damages attributable to a nonparty tortfeasor can be reallocated under Minn. Stat. 604.02(2). The court of appeals affirmed the reallocation. The Supreme Court reversed, holding that a party who is severally liable under section 604.02(1) cannot be ordered to contribute more than that party’s equitable share of the total damages award through the reallocation-of-damages provision in section 604.02(2). Remanded.