Minn. Stat. » CHAPTER 548. JUDGMENTS
Minnesota Statutes

Minn. Stat. § 548.36 (2026)

[Repealed]

✓ current as of May 2026
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MS 2006 [Renumbered 548.251]

Notes of Decisions
Cited in 65 cases, 1987–2015 · leading case: Heine v. Simon, 702 N.W.2d 752 (Minn. 2005).
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Heine v. Simon, 702 N.W.2d 752 (Minn. 2005). · cites it 82× “With her motions for costs and remittitur, Simon made a motion for collateral source offset under Minn.Stat. § 548.36, which the court granted in part and denied in part.”
Imlay v. City of Lake Crystal, 453 N.W.2d 326 (Minn. 1990). · cites it 38× “The court found all the insurance payments constituted collateral sources under Minn. Stat. § 548.36 (1986), but only deducted from the total verdict the $703,326.”
Kroning v. State Farm Auto. Ins. Co., 567 N.W.2d 42 (Minn. 1997). · cites it 20× “In 1986, the legislature enacted Minn.Stat. § 548.36, subd. 5, which specifically provides that "[t]he jury shall not be informed of the existence of collateral sources [of income] or any future benefits which may or may not be payable to the plaintiff.”
Folstad v. Eder, 467 N.W.2d 608 (Minn. 1991). · cites it 18× “6 (1990) or the collateral source deduction of Minn. Stat. § 548.36 (1990) apply? The trial court thought the collateral source deduction applied and the court of appeals thought the allocation formula governed.”
Lee v. Hunt, 642 N.W.2d 57 (Minn. Ct. App. 2002). · cites it 33× “Appellant objected to the timeliness of the motion, arguing that the ten-day deadline of the collateral source statute, Minn.Stat. § 548.36, subd. 2 (2000), applies to motions for deductions brought pursuant to the no-fault act and that, therefore, the motion to amend the…”
Keenan v. Hydra-Mac, Inc., 434 N.W.2d 463 (Minn. 1989). · cites it 22× “Prom’s Auto Salvage, the trial court, applying Minn.Stat. § 548.36, reduced the damage award by deducting much of the workers’ compensation benefits paid to the plaintiff up to the time of trial.”
Rush v. Jostock, 710 N.W.2d 570 (Minn. Ct. App. 2006). · cites it 19× “Minn.Stat. § 548.36 (2004) states, in pertinent part: Subd.”
Johnson v. Consol. Freightways, Inc., 420 N.W.2d 608 (Minn. 1988). · cites it 6× “Similarly, Minn.Stat. § 548.36, subds. 2, 3 (1986), requires the trial court, on motion from a party, to reduce the award in any civil action by amounts of collateral sources paid for plaintiff’s benefit.”
W. Nat'l Mut. Ins. Co. v. Casper, 549 N.W.2d 914 (Minn. 1996). · cites it 16× “Western National contends, however, that the adoption in 1986 of Minn.Stat. § 548.36, which deals with collateral source payments, has so undermined the rationale of Fryer and Brunmeier that we should now overrule or modify them.”
Koch v. Mork Clinic, P.A., 540 N.W.2d 526 (Minn. Ct. App. 1995). · cites it 30× “Because ERISA preempts Minn.Stat. § 548.36, the collateral source offset should be reinstated, and we affirm the judgment as modified.”
Casper v. City of Stacy, 473 N.W.2d 902 (Minn. Ct. App. 1991). · cites it 30× “Minn.Stat. § 548.36, subds. 2 & 3(a) (1988) provides that in civil actions, “[t]he court shall reduce the award by the amounts” obtained from collateral sources.”
Swanson v. Brewster, 784 N.W.2d 264 (Minn. 2010). · cites it 4× “NOTES [1] The original collateral-source statute, Minn. Stat. § 548.36 (2006), was renumbered to Minn.”
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— Minn. Stat. § 548.36(3) — 1 case
Gill v. MacIejewski, 546 F.3d 557 (8th Cir. 2008).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.