zone of danger test (Minnesota) · Go Syfert
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zone of danger test in Minnesota

7 Minnesota opinions name it 2 courts 1985–2013 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 (9)

CaseFollowedCited
Stadler v. Crossgreen
minn · 1980 · cited in 2 Minnesota opinions naming this issue, 1994–2005
2 sentences

2005We further noted that workable, reasonable, and logical limits must be placed on a negligent tortfeasor’s liability and observed that the zone of danger test provides just such clear limits because “juries can objectively determine whether plaintiffs were within the zone of danger.” Id. at 554 .

2005In contrast with the zone of danger test, “[njone of the other proposed limitations can be as readily and consistently applied.” Id.

22
Okrina v. Midwestern Corporationgreen
minn · 1969 · cited in 2 Minnesota opinions naming this issue, 1985–1995
2 sentences

1985Two Minnesota cases allowing recovery for emotional distress fit squarely under the zone of danger rule: Purcell and Okrina v. Midwestern Corp., 282 Minn. 400 , 165 N.W.2d 259 (1969).

1985Two Minnesota cases allowing recovery for emotional distress fit squarely under the zone of danger rule: Purcell and Okrina v. Midwestern Corp., 282 Minn. 400 , 165 N.W.2d 259 (1969).

12
Nielson v. AT & T CORP.green
sd · 1999 · cited in 1 Minnesota opinions naming this issue, 2005–2005
2 sentences

2005See, e.g., Nielson v. AT & T Corp., 597 N.W.2d 434, 442 (S.D.1999).

2005See, e.g., Bovsun, 473 N.Y.S.2d 357 , 461 N.E.2d at 847 (noting that “by unreasonably endangering the plaintiffs physical safety, the defendant has breached a duty owed to [the plaintiff] for which he or she should recover all damages sustained including those occasioned by witnessing the suffering of [another] who is also injured by the defendant’s conduct”); Nielson, 597 N.W.2d at 441 (“The rationale for the test is that the defendant breached a duty to the bystander by endangering her safety and placing her in the zone of danger.”).

11
Asaro v. Cardinal Glennon Memorial Hospitalgreen
mo · 1990 · cited in 1 Minnesota opinions naming this issue, 2005–2005
2 sentences

2005See Williams v. Baker, 572 A.2d 1062, 1064 (D.C.1990); Asaro v. Cardinal Glennon Mem'l Hosp., 799 S.W.2d 595, 599-600 (Mo.1990).

2005See Williams v. Baker, 572 A.2d 1062, 1064 (D.C.1990); Asaro v. Cardinal Glennon Mem’l Hosp., 799 S.W.2d 595, 599-600 (Mo.1990).

11
Williams v. Bakergreen
dc · 1990 · cited in 1 Minnesota opinions naming this issue, 2005–2005
2 sentences

2005See Williams v. Baker, 572 A.2d 1062, 1064 (D.C.1990); Asaro v. Cardinal Glennon Mem'l Hosp., 799 S.W.2d 595, 599-600 (Mo.1990).

2005See Williams v. Baker, 572 A.2d 1062, 1064 (D.C.1990); Asaro v. Cardinal Glennon Mem’l Hosp., 799 S.W.2d 595, 599-600 (Mo.1990).

11
Bovsun v. Sanperigreen
ny · 1984 · cited in 1 Minnesota opinions naming this issue, 2005–2005
2 sentences

2005See, e.g., Bovsun, 473 N.Y.S.2d 357 , 461 N.E.2d at 847 (noting that “by unreasonably endangering the plaintiffs physical safety, the defendant has breached a duty owed to [the plaintiff] for which he or she should recover all damages sustained including those occasioned by witnessing the suffering of [another] who is also injured by the defendant’s conduct”); Nielson, 597 N.W.2d at 441 (“The rationale for the test is that the defendant breached a duty to the bystander by endangering her safety and placing her in the zone of danger.”).

2005See, e.g., Bovsun, 473 N.Y.S.2d 357 , 461 N.E.2d at 847 (noting that “by unreasonably endangering the plaintiffs physical safety, the defendant has breached a duty owed to [the plaintiff] for which he or she should recover all damages sustained including those occasioned by witnessing the suffering of [another] who is also injured by the defendant’s conduct”); Nielson, 597 N.W.2d at 441 (“The rationale for the test is that the defendant breached a duty to the bystander by endangering her safety and placing her in the zone of danger.”).

11
Soucek v. Banhamgreen
minnctapp · 1993 · cited in 1 Minnesota opinions naming this issue, 1995–1995
1 sentence

1995Soucek v. Banham, 503 N.W.2d 153, 163 (Minn.App.1993).

11
Leaon v. Washington Countygreen
minn · 1986 · cited in 1 Minnesota opinions naming this issue, 1995–1995
2 sentences

1995Langeland v. Farmers State Bank of Trimont, 319 N.W.2d 26, 31 (Minn.1982); see also Leaon v. Washington County, 397 N.W.2d 867, 875 (Minn.1986).

1995Langeland v. Farmers State Bank of Trimont, 319 N.W.2d 26, 31 (Minn.1982); see also Leaon v. Washington County, 397 N.W.2d 867, 875 (Minn.1986).

11
Langeland v. Farmers State Bank of Trimontgreen
minn · 1982 · cited in 1 Minnesota opinions naming this issue, 1995–1995
2 sentences

1995Langeland v. Farmers State Bank of Trimont, 319 N.W.2d 26, 31 (Minn.1982); see also Leaon v. Washington County, 397 N.W.2d 867, 875 (Minn.1986).

1995Langeland v. Farmers State Bank of Trimont, 319 N.W.2d 26, 31 (Minn.1982); see also Leaon v. Washington County, 397 N.W.2d 867, 875 (Minn.1986).

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 (1)

CaseCitedYears
Bohdan v. Alltool Mfg., Co. green
minnctapp · 1987
2 sentences

2013The only exception to the zone-of-danger rule is when a plaintiff experiences mental anguish or suffering resulting from “a direct invasion of his rights, such as defamation, malicious prosecution, or other willful, wanton or malicious conduct.” Id.

1996Id.

21996–2013

Where else courts name it

NY 26 (1969–2025) PA 21 (1976–2022) IL 18 (1985–2021) DC 14 (1988–2015) AL 9 (1998–2012) OH 7 (1983–2023) MN 7 (1985–2013) LA 5 (1993–2021) UT 5 (1992–2024) NE 5 (1985–2024) CA 5 (1968–1989) NH 4 (1979–2003) TN 4 (1996–2017) CT 4 (1994–2017) MO 4 (1990–2008) VT 4 (2016–2025) IA 3 (1981–2025) DE 3 (1983–2025) OR 3 (1986–2016) ME 3 (1982–2015) TX 3 (1997–2016) MA 3 (1978–1998) GA 3 (2009–2012) NM 3 (1990–1996) MD 2 (1995–2012) ND 2 (1972–1988) WA 2 (2017–2025) HI 2 (1974–1992) CO 2 (1986–1996) KS 2 (1994–2008) NV 2 (1985–1998)

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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