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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Molenaar v. United Cattle Co., 553 N.W.2d 424 (1996)

Citation
Molenaar v. United Cattle Co., 553 N.W.2d 424 (1996)
Parent Document
Molenaar v. United Cattle Co., 553 N.W.2d 424 (1996)
Jurisdiction
Minnesota (state)
Effective Date
1996-07-30

Other Sections in This Document (93)

Full Text

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*428 In 1980 the supreme court extended the scope of punitive damages in Minnesota to include strict products-liability cases. Gryc v. Dayton-Hudson Corp., 297 N.W.2d 727, 741 (Minn.), cert. denied, 449 U.S. 921, 101 S.Ct. 320, 66 L.Ed.2d 149 (1980). This extension shifted the focus from a defendant's conduct to the severity of a plaintiff's injuries and removed the requirement of clear and convincing evidence of willful indifference to the rights or safety of others. In 1982 the court limited this expansion by prohibiting punitive damages in strict products-liability cases absent personal injury. Eisert v. Greenberg Roofing & Sheet Metal, 314 N.W.2d 226, 229 (Minn.1982) (noting the "extraordinary measure of deterrence" of punitive damages in strict liability cases).