collateral source rule (Minnesota) · Go Syfert
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collateral source rule in Minnesota

17 Minnesota opinions name it 2 courts 1980–2016 0 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 (12)

CaseFollowedCited
Hubbard Broadcasting, Inc. v. Loeschergreen
minn · 1980 · cited in 4 Minnesota opinions naming this issue, 1982–2016
2 sentences

2016“The collateral source rule, if applied to an action based on breach of contract, would violate the contractual damage rule that no one shall profit more from the breach of an obligation than from its full performance.” Id. at 223 (quotation omitted).

2003Under the collateral-source rule, “in general, * * * compensation received from a third party will not diminish recovery against a wrongdoer.” Hubbard Broad., Inc. v. Loescher, 291 N.W.2d 216, 222 (Minn.1980).

44
Buck v. Schneidergreen
minnctapp · 1987 · cited in 4 Minnesota opinions naming this issue, 1992–2009
2 sentences

2009See Kahnke v. Green, 695 N.W.2d 148, 151-52 (Minn.App.2005) (finding that subrogation rights were asserted in a timely fashion when the plaintiff raised the subrogation rights at the collateral-source hearing); Buck v. Schneider, 413 N.W.2d 569, 571 (Minn.App.1987) (finding that the plaintiff asserted subrogation rights “by stating, in response to the court’s order requiring the parties to submit evidence of collateral sources, and in responses to discovery requests, that he had been assigned those rights”).

1995In determining the applicability of the collateral source rule under slightly different circumstances we have held: Because the primary purpose of this statute is to prevent double recoveries, no deduction is allowed where subrogation rights are asserted “to ensure that the amount of collateral sources deducted from the award is the amount to which the plaintiff is actually entitled, and does not include amounts plaintiff must ultimately pay over to a subrogee.” Imlay v. City of Lake Crystal, 453 N.W.2d 326, 334 (Minn.1990) (citing Buck v. Schneider, 413 N.W.2d 569, 572 (Minn.App.1987)).

34
Hueper v. Goodrichgreen
minn · 1982 · cited in 4 Minnesota opinions naming this issue, 1984–2010
2 sentences

2010The collateral-source rule applies in a variety of contexts, including “insurance proceeds, employment benefits, gifts of money or medical services, welfare benefits or tax advantages.” Hueper v. Goodrich, 314 N.W.2d 828, 830 (Minn.1982) (medical services provided free of charge); see, e.g., Van Tassel v. Horace Mann Ins.

2010The collateral-source rule applies in a variety of contexts, including "insurance proceeds, employment benefits, gifts of money or medical services, welfare benefits or tax advantages." Hueper v. Goodrich, 314 N.W.2d 828, 830 (Minn.1982) (medical services provided free of charge); see, e.g., Van Tassel v. Horace Mann Ins.

24
Van Tassel v. Horace Mann Insurance Companygreen
minn · 1973 · cited in 2 Minnesota opinions naming this issue, 1997–2010
2 sentences

2010Co., 296 Minn. 181, 188-89 , 207 N.W.2d 348, 352-53 (1973) (insurance); Local 1140, Int’l Union of Elec., Radio & Mach.

2010Co., 296 Minn. 181, 188-89 , 207 N.W.2d 348, 352-53 (1973) (insurance); Local 1140, Int’l Union of Elec., Radio & Mach.

22
Imlay v. City of Lake Crystalgreen
minn · 1990 · cited in 2 Minnesota opinions naming this issue, 1991–1995
2 sentences

1995In determining the applicability of the collateral source rule under slightly different circumstances we have held: Because the primary purpose of this statute is to prevent double recoveries, no deduction is allowed where subrogation rights are asserted “to ensure that the amount of collateral sources deducted from the award is the amount to which the plaintiff is actually entitled, and does not include amounts plaintiff must ultimately pay over to a subrogee.” Imlay v. City of Lake Crystal, 453 N.W.2d 326, 334 (Minn.1990) (citing Buck v. Schneider, 413 N.W.2d 569, 572 (Minn.App.1987)).

1991Imlay v. City of Lake Crystal, 453 N.W.2d 326, 331 (Minn.1990).

22
Mitchell v. Haldargreen
del · 2005 · cited in 1 Minnesota opinions naming this issue, 2010–2010
2 sentences

2010Lopez v. Safeway Stores, Inc., 212 Ariz. 198 , 129 P.3d 487, 495 (2006); see also Mitchell v. Haldar, 883 A.2d 32, 40 (Del.2005); Brown v. Van Noy, 879 S.W.2d 667, 676 (Mo.Ct.App.1994) (“[T]he fact that the expenses were ‘taken care of by Medicare is not materially different than expenses paid by insurance or paid in part by insurance with part ‘written off pursuant to a contract or agreement between the medical provider and the insurance company.”).

2010Lopez v. Safeway Stores, Inc., 212 Ariz. 198 , 129 P.3d 487, 495 (2006); see also Mitchell v. Haldar, 883 A.2d 32, 40 (Del.2005); Brown v. Van Noy, 879 S.W.2d 667, 676 (Mo.Ct.App. 1994) ("[T]he fact that the expenses were `taken care of' by Medicare is not materially different than expenses paid by insurance or paid in part by insurance with part `written off' pursuant to a contract or agreement between the medical provider and the insurance company.").

11
Brown v. Van Noygreen
moctapp · 1994 · cited in 1 Minnesota opinions naming this issue, 2010–2010
2 sentences

2010Lopez v. Safeway Stores, Inc., 212 Ariz. 198 , 129 P.3d 487, 495 (2006); see also Mitchell v. Haldar, 883 A.2d 32, 40 (Del.2005); Brown v. Van Noy, 879 S.W.2d 667, 676 (Mo.Ct.App.1994) (“[T]he fact that the expenses were ‘taken care of by Medicare is not materially different than expenses paid by insurance or paid in part by insurance with part ‘written off pursuant to a contract or agreement between the medical provider and the insurance company.”).

2010Lopez v. Safeway Stores, Inc., 212 Ariz. 198 , 129 P.3d 487, 495 (2006); see also Mitchell v. Haldar, 883 A.2d 32, 40 (Del.2005); Brown v. Van Noy, 879 S.W.2d 667, 676 (Mo.Ct.App. 1994) ("[T]he fact that the expenses were `taken care of' by Medicare is not materially different than expenses paid by insurance or paid in part by insurance with part `written off' pursuant to a contract or agreement between the medical provider and the insurance company.").

11
Koffman v. Leichtfussgreen
wis · 2001 · cited in 1 Minnesota opinions naming this issue, 2010–2010
2 sentences

2010Hoffman v. Leichtfuss, 246 Wis.2d 31 , 630 N.W.2d 201, 210 (2001).

2010Hoffman v. Leichtfuss, 246 Wis.2d 31 , 630 N.W.2d 201, 210 (2001).

11
Lopez v. Safeway Stores, Inc.green
arizctapp · 2006 · cited in 1 Minnesota opinions naming this issue, 2010–2010
2 sentences

2010Lopez v. Safeway Stores, Inc., 212 Ariz. 198 , 129 P.3d 487, 495 (2006); see also Mitchell v. Haldar, 883 A.2d 32, 40 (Del.2005); Brown v. Van Noy, 879 S.W.2d 667, 676 (Mo.Ct.App.1994) (“[T]he fact that the expenses were ‘taken care of by Medicare is not materially different than expenses paid by insurance or paid in part by insurance with part ‘written off pursuant to a contract or agreement between the medical provider and the insurance company.”).

2010Lopez v. Safeway Stores, Inc., 212 Ariz. 198 , 129 P.3d 487, 495 (2006); see also Mitchell v. Haldar, 883 A.2d 32, 40 (Del.2005); Brown v. Van Noy, 879 S.W.2d 667, 676 (Mo.Ct.App.1994) (“[T]he fact that the expenses were ‘taken care of by Medicare is not materially different than expenses paid by insurance or paid in part by insurance with part ‘written off pursuant to a contract or agreement between the medical provider and the insurance company.”).

11
Kahnke v. Greengreen
minnctapp · 2005 · cited in 1 Minnesota opinions naming this issue, 2009–2009
1 sentence

2009See Kahnke v. Green, 695 N.W.2d 148, 151-52 (Minn.App.2005) (finding that subrogation rights were asserted in a timely fashion when the plaintiff raised the subrogation rights at the collateral-source hearing); Buck v. Schneider, 413 N.W.2d 569, 571 (Minn.App.1987) (finding that the plaintiff asserted subrogation rights “by stating, in response to the court’s order requiring the parties to submit evidence of collateral sources, and in responses to discovery requests, that he had been assigned those rights”).

11
Dean v. American Family Mutual Insurance Co.green
minn · 1995 · cited in 1 Minnesota opinions naming this issue, 2008–2008
1 sentence

2008Dean, 535 N.W.2d at 344 (“[B]oth the collateral source rule and the UIM provisions were meant to avoid double recovery.”).

11
Patent Scaffolding Co. v. William Simpson Construction Co.green
calctapp · 1967 · cited in 1 Minnesota opinions naming this issue, 1980–1980
2 sentences

1980Co., 256 Cal.App.2d 506, 511 , 64 Cal.Rptr. 187, 191 (1967): The collateral source rule is, punitive; contractual damages are compensatory. *223 The collateral source rule, if applied to an action based on breach of contract, would violate the contractual damage rule that no one shall profit more from the breach of an obligation than from its full performance.

1980Co., 256 Cal.App.2d 506, 511 , 64 Cal.Rptr. 187, 191 (1967): The collateral source rule is, punitive; contractual damages are compensatory. *223 The collateral source rule, if applied to an action based on breach of contract, would violate the contractual damage rule that no one shall profit more from the breach of an obligation than from its full performance.

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 (8)

CaseCitedYears
Smith v. American States Insurance Co. green
minnctapp · 1998
1 sentence

2008The Dean court acknowledges that it considers the limited issue of whether “an automobile accident liability insurance payment from an underinsured tortfeasor triggers the collateral source rule in a claim for [UIM] benefits when the claimant is partially at fault.” Id. at 343 .

12008–2008
Stout v. AMCO Insurance Co. green
minn · 2002
1 sentence

2004In Stout , the court held that a claimant may assert a claim against a no-fault carrier for the full amount of medical expenses incurred by the claimant regardless of whether that amount was subsequently reduced as a result of collateral transactions involving the claimant’s health insurer. 645 N.W.2d at 113 .

12004–2004
Duluth Steam Cooperative Ass'n v. Ringsred green
minnctapp · 1994
1 sentence

2003Ringsred, 519 N.W.2d at 217 .

12003–2003
Bartosch v. Lewison green
minnctapp · 1987
2 sentences

1997Today, the court adopts the exception to the collateral source rule set out by the court of appeals in Bartosch v. Lewison, 1 413 N.W.2d 530 (Minn.App.1987), and holds that a defendant may rebut a plaintiffs claim of financial destitution by presenting evidence of collateral source payments received by the plaintiff.

1997Today, the court adopts the exception to the collateral source rule set out by the court of appeals in Bartosch v. Lewison , [1] 413 N.W.2d 530 (Minn.App.1987), and holds that a defendant may rebut a plaintiff's claim of financial destitution by presenting evidence of collateral source payments received by the plaintiff.

11997–1997
Austin v. State Farm Mutual Automobile Insurance green
minnctapp · 1992
2 sentences

1994Two years later, in Austin , we cited our decision in Kersting and rejected nearly the same argument — that the collateral source rule required offsetting an arbitration award by the amount the injured party received through workers' compensation. 486 N.W.2d at 459 .

1994Two years later, in Austin , we cited our decision in Kersting and rejected nearly the same argument — that the collateral source rule required offsetting an arbitration award by the amount the injured party received through workers’ compensation. 486 N.W.2d at 459 .

11994–1994
Folstad v. Eder green
minn · 1991
1 sentence

1993Thus, if the subrogated damages have been separated out of Krutsch’s action, there is no need to apply the collateral source rule.' See id.

11993–1993
Kersting v. Royal-Milbank Insurance green
minnctapp · 1990
2 sentences

1992This court rejected the same argument in Kersting v. Royal-Milbank Ins., 456 N.W.2d 270 (Minn.App.1990).

1992We recognized in Kersting, 456 N.W.2d at 274 , that there were competing public policies which would have been furthered by requiring the trial court to apply the collateral source rule to arbitration awards. [Appellant] argues that the policy against double recovery is violated if the arbitration award is not modified in this case.

11992–1992
Dahlin v. Kron green
minn · 1950
2 sentences

1982To the extent Dahlin v. Kron, 232 Minn. 312 , 45 N.W.2d 833 (1950), suggests otherwise, it should not be followed.

1982To the extent Dahlin v. Kron, 232 Minn. 312 , 45 N.W.2d 833 (1950), suggests otherwise, it should not be followed.

11982–1982

Statutes the citing opinions construe

MN § Minn. Stat. § 548.36 (11) MN § Minn. Stat. § 176.061 (3) MN § Minn. Stat. § 604.01 (3) MN § Minn. Stat. § 645.16 (3) MN § Minn. Stat. § 65B.42 (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

CA 138 (1967–2026) IL 105 (1973–2026) LA 97 (1977–2025) TX 86 (1969–2026) OH 64 (1966–2023) GA 62 (1970–2025) PA 55 (1971–2024) NY 53 (1962–2026) FL 52 (1968–2026) CO 52 (1971–2026) MO 47 (1968–2023) WI 46 (1972–2026) WA 45 (1978–2024) NJ 42 (1968–2025) VA 38 (1986–2023) AZ 37 (1967–2025) CT 34 (1970–2021) SC 32 (1967–2025) MD 28 (1968–2022) MI 28 (1973–2019) AL 28 (1977–2025) MA 24 (1974–2024) MS 24 (1981–2023) DE 23 (1964–2026) AR 22 (1972–2017) WV 22 (1973–2025) KS 22 (1982–2019) IA 20 (1974–2019) NM 20 (1974–2024) KY 18 (1974–2025) NC 18 (1982–2021) MN 17 (1980–2016) ME 17 (1978–2022) RI 16 (1966–2013) TN 15 (1994–2025) OK 15 (1977–2023) IN 15 (1971–2015) OR 14 (1972–2026) NV 12 (1996–2024) VT 11 (1983–2024) NE 11 (1989–2019) AK 10 (1967–2022) UT 10 (1997–2026) DC 10 (1978–2024) SD 8 (1975–2009) MT 8 (1972–2000) WY 7 (1986–2002) HI 7 (1999–2025) NH 6 (1980–2018) ND 4 (1978–1999) ID 4 (1979–1991)

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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