Schroeder v. Western Nat’l Mut. Ins. Co.
Annotate this CaseRespondent suffered a significant injury in a motor vehicle accident and was totally disabled for approximately five months. During her period of disability, Respondent was unable to perform most household duties. Respondent later filed a claim for replacement service loss benefits with her no-fault insurance provider, Western National Mutual Insurance Co. (Appellant), alleging that she was entitled to the reasonable value of the home care and maintenance services she was unable to perform. Appellant refused to pay Respondent’s claim, asserting that it would not reimburse Respondent for household services that were not replaced in some way. An arbitrator awarded Respondent’s entire claim. The district court denied Appellant’s motion to vacate the arbitration award. The court of appeals affirmed, concluding that Minn. Stat. 65B.44(5) does not require replacement of household services when the injured person is primarily responsible for household duties. The Supreme Court affirmed, holding that an injured person who has primary responsibility for care and maintenance of the household need not replace household services as a condition to recovering the reasonable value of such services under section 65B.44(5).
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