adequacy warning (Minnesota) · Go Syfert
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adequacy warning in Minnesota

22 Minnesota opinions name it 2 courts 1984–2024 1 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
Balder v. Haleygreen
minn · 1987 · cited in 6 Minnesota opinions naming this issue, 1987–2004
2 sentences

2004Balder v. Haley, 399 N.W.2d 77, 81 (Minn.1987).

2003Balder v. Haley, 399 N.W.2d 77, 81 (Minn.1987).

56
Germann v. F.L. Smithe MacHine Co.green
minn · 1986 · cited in 2 Minnesota opinions naming this issue, 1987–2012
2 sentences

2012Germann, 395 N.W.2d at 924 .

2012Pouliot, 582 N.W.2d at 224 ; Germann, 395 N.W.2d at 924-25 .

12
Ralph M. Johnson v. Niagara MacHine & Tool Works, a New York Corporationgreen
ca8 · 1981 · cited in 2 Minnesota opinions naming this issue, 1992–1993
2 sentences

1993The court explained that “an issue as to the adequacy of a warning necessarily presupposes that the operator had read the warning.” Id.

1992Although there is no Minnesota case which specifically holds that the adequacy of a warning cannot be reviewed without a showing of reliance on the warning, the Eighth Circuit Court of Appeals has held that “an issue as to the adequacy of a warning necessarily presupposes that the operator has read the warning.” Johnson v. Niagara Mach. & Tool Works, 666 F.2d 1223, 1225 (8th Cir.1981).

12
Cipollone v. Liggett Group, Inc.green
ca3 · 1986 · cited in 2 Minnesota opinions naming this issue, 1989–1991
2 sentences

1991As a rule, courts allow preemption of state tort claims in cases where a state law creates a “state imposed regulatory scheme superimposed on the federal scheme.” Forster, 437 N.W.2d at 659 (holding that state tort claims based on a state-imposed duty to warn are impliedly preempted because they allow a state court to reevaluate the adequacy of the federal duty to warn in each case); see also Cippollone v. Liggett Group, Inc., 789 F.2d 181 , 187 (3rd Cir.1986) (federal Cigarette Labeling and Advertising Act preempts state damage actions which challenge the adequacy of the warnings or the propr

1989Reynolds relies on the leading case of Cipollone v. Liggett Group, Inc., 789 F.2d 181 (3d Cir.1986), cert. denied, 479 U.S. 1043 , 107 S.Ct. 907 , 93 L.Ed.2d 857 (1987), which holds that the federal Act preempts those state tort claims “that challenge either the adequacy of the warning on cigarette packages or the propriety of a party’s actions with respect to the advertising and promotion of cigarettes.” Id. at 187 (citation omitted).

12
State v. Garibaldigreen
minnctapp · 2007 · cited in 1 Minnesota opinions naming this issue, 2024–2024
1 sentence

2024See State v. Garibaldi, 726 N.W.2d 823 , 826–31 (Minn. App. 2007) (collecting cases).

11
State v. Pilchergreen
minn · 1991 · cited in 1 Minnesota opinions naming this issue, 2016–2016
2 sentences

2016Farnsworth, 738 N.W.2d at 373 ; State v. Pilcher, 472 N.W.2d 327, 333 (Minn. 1991).

2016In determining whether a defendant’s statement was voluntary, we consider the nature of the interview, including its length, the adequacy of warnings, whether the defendant’s physical needs were met, and whether the defendant was denied access to friends., Farnsworth, 738 N.W.2d at 373 ; State v. Pilcher, 472 N.W.2d 327, 333 (Minn.1991).

11
Henning v. Union Pacific Railroadgreen
ca10 · 2008 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014R.R., 530 F.3d 1206, 1216 (10th Cir. 2008) (holding that inadequacy-of-warning claim preempted despite 2007 amendment); see also Zimmerman v. Norfolk S. Corp., 706 F. 3d 170, 188-93 (3rd Cir. 2013) (holding tort claim that railroad failed to maintain warning sign not preempted, but inadequacy-of-warning-sign claim preempted).

11
Robert Zimmerman v. Norfolk Southern Corporationgreen
ca3 · 2013 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014R.R., 530 F.3d 1206, 1216 (10th Cir. 2008) (holding that inadequacy-of-warning claim preempted despite 2007 amendment); see also Zimmerman v. Norfolk S. Corp., 706 F. 3d 170, 188-93 (3rd Cir. 2013) (holding tort claim that railroad failed to maintain warning sign not preempted, but inadequacy-of-warning-sign claim preempted).

11
Dahlbeck v. DICO Co., Inc.green
minnctapp · 1984 · cited in 1 Minnesota opinions naming this issue, 2011–2011
1 sentence

2011Dahlbeck v. DICO Co., 355 N.W.2d 157, 163 (Minn.App.1984), review denied (Minn. Feb. 6, 1985).

11
State v. Hintongreen
minnctapp · 2005 · cited in 1 Minnesota opinions naming this issue, 2010–2010
1 sentence

2010See State v. Hinton, 702 N.W.2d 278, 281-82 (Minn.App.2005) (applying harmless-error test), review denied (Minn. Oct. 26, 2005); see also State v. Wright, 679 N.W.2d 186 (Minn.App.2004) (stipulating to element of age), review denied (Minn. June 29, 2004).

11
State v. Wrightgreen
minnctapp · 2004 · cited in 1 Minnesota opinions naming this issue, 2010–2010
1 sentence

2010See State v. Hinton, 702 N.W.2d 278, 281-82 (Minn.App.2005) (applying harmless-error test), review denied (Minn. Oct. 26, 2005); see also State v. Wright, 679 N.W.2d 186 (Minn.App.2004) (stipulating to element of age), review denied (Minn. June 29, 2004).

11
State v. Williamsgreen
minn · 1995 · cited in 1 Minnesota opinions naming this issue, 2009–2009
2 sentences

2009State v. Williams, 535 N.W.2d 277, 287 (Minn.1995).

2009State v. Williams, 535 N.W.2d 277, 287 (Minn.1995).

11
State v. Camachogreen
minn · 1997 · cited in 1 Minnesota opinions naming this issue, 2006–2006
1 sentence

2006State v. Camacho, 561 N.W.2d 160, 168 (Minn.1997).

11
Augustine v. Hitzmangreen
minn · 1970 · cited in 1 Minnesota opinions naming this issue, 1993–1993
2 sentences

1993See Augustine v. Hitzman, 287 Minn. 311, 314 , 178 N.W.2d 227, 229 (1970) (“A higher degree of care is required with respect to children than with respect to adults.”) After finding that the manufacturer had a duty to warn, “issues such as the adequacy of the warning, breach, and causation” are for the jury to resolve.

1993See Augustine v. Hitzman, 287 Minn. 311, 314 , 178 N.W.2d 227, 229 (1970) (“A higher degree of care is required with respect to children than with respect to adults.”) After finding that the manufacturer had a duty to warn, “issues such as the adequacy of the warning, breach, and causation” are for the jury to resolve.

11
Forster v. R.J. Reynolds Tobacco Co.green
minn · 1989 · cited in 1 Minnesota opinions naming this issue, 1991–1991
1 sentence

1991As a rule, courts allow preemption of state tort claims in cases where a state law creates a “state imposed regulatory scheme superimposed on the federal scheme.” Forster, 437 N.W.2d at 659 (holding that state tort claims based on a state-imposed duty to warn are impliedly preempted because they allow a state court to reevaluate the adequacy of the federal duty to warn in each case); see also Cippollone v. Liggett Group, Inc., 789 F.2d 181 , 187 (3rd Cir.1986) (federal Cigarette Labeling and Advertising Act preempts state damage actions which challenge the adequacy of the warnings or the propr

11
Richard Leander Ferebee, Jr. v. Chevron Chemical Companygreen
cadc · 1984 · cited in 1 Minnesota opinions naming this issue, 1991–1991
1 sentence

1991Only one case, Ferebee v. Chevron Chemical Co., 736 F.2d 1529, 1541-42 (D.C.Cir.1984), has explicitly allowed state tort claims for damages arising from the failure to warn even though the actions create stricter standards under state law than the federal law required.

11
Lindquist v. Tambrands, Inc.green
mnd · 1989 · cited in 1 Minnesota opinions naming this issue, 1991–1991
1 sentence

1991As a rule, courts allow preemption of state tort claims in cases where a state law creates a “state imposed regulatory scheme superimposed on the federal scheme.” Forster, 437 N.W.2d at 659 (holding that state tort claims based on a state-imposed duty to warn are impliedly preempted because they allow a state court to reevaluate the adequacy of the federal duty to warn in each case); see also Cippollone v. Liggett Group, Inc., 789 F.2d 181 , 187 (3rd Cir.1986) (federal Cigarette Labeling and Advertising Act preempts state damage actions which challenge the adequacy of the warnings or the propr

11
cluster 372611green
ca8 · 1979 · cited in 1 Minnesota opinions naming this issue, 1984–1984
1 sentence

1984The multitudes of switches offered by Cutler-Hammer could be used in many different ways. “[A] purchaser of multi-use equipment knows best the dangers associated with its particular use, and so it should determine the degree of safety provided.” Wagner v. International Harvester Co., 611 F.2d 224, 231 (8th Cir.1979).

11
cluster 332474green
ca5 · 1976 · cited in 1 Minnesota opinions naming this issue, 1984–1984
1 sentence

1984The adequacy of a warning “cannot be evaluated apart from the knowledge and expertise of those who may reasonably be expected to use or otherwise come in contact with the product....” Martinez v. Dixie Carriers, Inc., 529 F.2d 457, 465-66 (5th Cir.1976), cited with approval in Strong, 667 F.2d at 687 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
State v. Farnsworth green
minn · 2007
2 sentences

2016Farnsworth, 738 N.W.2d at 373 ; State v. Pilcher, 472 N.W.2d 327, 333 (Minn. 1991).

2016In determining whether a defendant’s statement was voluntary, we consider the nature of the interview, including its length, the adequacy of warnings, whether the defendant’s physical needs were met, and whether the defendant was denied access to friends., Farnsworth, 738 N.W.2d at 373 ; State v. Pilcher, 472 N.W.2d 327, 333 (Minn.1991).

12016–2016
State v. Needham green
minn · 1992
1 sentence

2015The supreme court reasoned that “the focus of the omnibus hearing was on other issues relating to the taking of the confession” and that “[i]t was not until the prosecutor received the defendant’s omnibus hearing brief, filed simultaneously with the state’s brief, that the prosecutor could know that the defense was making an issue of the adequacy of the warning given defendant.” Id.

12015–2015
Pouliot v. Fitzsimmons green
minn · 1998
1 sentence

2012Pouliot, 582 N.W.2d at 224 ; Germann, 395 N.W.2d at 924-25 .

12012–2012
Dosdall v. Smith green
minnctapp · 1987
2 sentences

1992The trial court, citing Dosdall v. Smith, 415 N.W.2d 332 (Minn.App.1987), agreed that the adequacy of a warning is a jury question but concluded that this would become an issue only if Born had read or relied in any way on the warning.

1992The trial court, citing Dosdall v. Smith, 415 N.W.2d 332 (Minn.App.1987), agreed that the adequacy of a warning is a jury question but concluded that this would become an issue only if Born had read or relied in any way on the warning.

11992–1992
State v. Linder green
minn · 1978
2 sentences

1989Id. at 735 .

1989The standard for determining the adequacy of a waiver was outlined by this court in State v. Linder, 268 N.W.2d 734 (Minn.1978): In an ordinary case if the prosecutor shows that the warning was given and that defendant stated he understood his rights and then gave a statement, the state will be deemed to have met its burden of proof, unless there is other evidence indicating that there was no knowing, intelligent, and voluntary waiver. * * * However, if there is other such evidence, then the trial court must make a subjective factual inquiry to determine whether under the totality of the circu

11989–1989
Martin County, Florida v. Makemson Et Al.; And Okeechobee County, Florida v. Dennis Et Al. green
scotus · 1987
2 sentences

1989Reynolds relies on the leading case of Cipollone v. Liggett Group, Inc., 789 F.2d 181 (3d Cir.1986), cert. denied, 479 U.S. 1043 , 107 S.Ct. 907 , 93 L.Ed.2d 857 (1987), which holds that the federal Act preempts those state tort claims “that challenge either the adequacy of the warning on cigarette packages or the propriety of a party’s actions with respect to the advertising and promotion of cigarettes.” Id. at 187 (citation omitted).

1989Reynolds relies on the leading case of Cipollone v. Liggett Group, Inc., 789 F.2d 181 (3d Cir.1986), cert. denied, 479 U.S. 1043 , 107 S.Ct. 907 , 93 L.Ed.2d 857 (1987), which holds that the federal Act preempts those state tort claims “that challenge either the adequacy of the warning on cigarette packages or the propriety of a party’s actions with respect to the advertising and promotion of cigarettes.” Id. at 187 (citation omitted).

11989–1989
Cipollone v. Liggett Group, Inc. green
scotus · 1987
1 sentence

1989Reynolds relies on the leading case of Cipollone v. Liggett Group, Inc., 789 F.2d 181 (3d Cir.1986), cert. denied, 479 U.S. 1043 , 107 S.Ct. 907 , 93 L.Ed.2d 857 (1987), which holds that the federal Act preempts those state tort claims “that challenge either the adequacy of the warning on cigarette packages or the propriety of a party’s actions with respect to the advertising and promotion of cigarettes.” Id. at 187 (citation omitted).

11989–1989
California v. Prysock green
scotus · 1981
2 sentences

1989We need not decide the issue of the adequacy of the warning under California v. Prysock, 453 U.S. 355 , 101 S.Ct. 2806 , 69 L.Ed.2d 696 (1981).

1989We need not decide the issue of the adequacy of the warning under California v. Prysock, 453 U.S. 355 , 101 S.Ct. 2806 , 69 L.Ed.2d 696 (1981).

11989–1989
cluster 398281 green
ca8 · 1981
1 sentence

1984The adequacy of a warning “cannot be evaluated apart from the knowledge and expertise of those who may reasonably be expected to use or otherwise come in contact with the product....” Martinez v. Dixie Carriers, Inc., 529 F.2d 457, 465-66 (5th Cir.1976), cited with approval in Strong, 667 F.2d at 687 .

11984–1984

Statutes the citing opinions construe

MN § Minn. Stat. § 609.185 (3) MN § Minn. Stat. § 609.19 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 172 (1935–2026) NY 130 (1953–2026) CA 78 (1954–2026) IL 57 (1970–2026) WA 48 (1968–2026) PA 46 (1971–2023) IN 43 (1979–2024) FL 43 (1972–2026) NJ 31 (1955–2025) LA 31 (1954–2024) MI 27 (1963–2022) MA 25 (1974–2025) OH 24 (1974–2026) MN 22 (1984–2024) OR 21 (1943–2024) NV 21 (1983–2022) MS 20 (1969–2017) CO 16 (1976–2021) WI 15 (1972–2026) MO 15 (1958–2019) CT 14 (1950–2016) AZ 14 (1947–2024) AL 13 (1983–2013) KS 13 (1984–2026) NM 13 (1975–2015) AR 12 (1992–2022) TN 11 (1985–2022) DC 11 (1968–2025) UT 11 (1989–2024) GA 10 (1982–2025) IA 10 (1986–2014) DE 9 (1985–2023) KY 9 (1968–2024) RI 9 (2000–2026) MD 8 (1968–2012) OK 7 (1975–2010) ID 6 (1979–2013) AK 6 (1973–2018) VA 5 (1985–2026) VT 5 (1990–2026) ND 5 (1909–1997) NC 4 (1975–2012) WY 4 (1992–2019) WV 4 (1979–2018) SC 4 (1973–2008) ME 3 (1981–2013) HI 3 (1999–2007) MT 3 (2000–2010) VI 2 (2002–2005)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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