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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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Finally, the supreme court's holding in Phelps v. Commonwealth Land Title Insurance Co., 537 N.W.2d 271, 276-77 (Minn. 1995), is not inconsistent with a rule that punitive damages may not be recovered absent personal injury. In Phelps, the plaintiff recovered $75,000 for mental anguish and suffering. Id. at 273. Mental suffering is a personal injury. See generally Michael K. Steenson, The Anatomy of Emotional Distress Claims in Minnesota, 19 Wm. Mitchell L.Rev. 1 (1993)(noting it is well-settled that damages for personal injury include a mental suffering component and discussing other causes of action where damages for mental suffering alone are recoverable). NOTES