Hartfiel v. McLennan

430 N.W.2d 215, 1988 Minn. App. LEXIS 971, 1988 WL 58695
CourtCourt of Appeals of Minnesota
DecidedOctober 11, 1988
DocketC5-88-884
StatusPublished
Cited by11 cases

This text of 430 N.W.2d 215 (Hartfiel v. McLennan) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hartfiel v. McLennan, 430 N.W.2d 215, 1988 Minn. App. LEXIS 971, 1988 WL 58695 (Mich. Ct. App. 1988).

Opinions

OPINION

NORTON, Judge.

Respondent Patricia Hartfiel commenced this garnishment action against appellant MSI Insurance Company in order to collect on a stipulated judgment entered against MSI’s insured, respondent Terry W. McLennan. The trial court granted partial summary judgment to strike two defenses which MSI asserted in its answer, but de[217]*217nied summary judgment as to the reasonableness of the stipulation. Judgment was thereafter entered by stipulation of the parties. We affirm in part, reverse in part and remand.

FACTS

On October 2,1976, Patricia Hartfiel was struck by Terry McLennan’s car while she was walking in the parking lot of Gloria’s 101 Club in Corcoran, Minnesota. On the date of the accident, McLennan had liability coverage regarding the operation of his vehicle through MSI Insurance Company.

MSI first received notice of the accident in a letter from an attorney retained by Hartfiel on February 14,1979. MSI denied liability coverage to McLennan in a letter dated June 5, 1979 due to its inability to adequately investigate the facts surrounding the accident because of McLennan’s failure to give timely notice. On December 4, 1979, Hartfiel commenced an action against McLennan for personal injuries which she received in the accident. Because MSI denied liability coverage, McLennan retained legal counsel on his own.

When MSI denied coverage of McLen-nan, Hartfiel sought uninsured motorist coverage from her insurer, Agricultural Insurance Company. Agricultural Insurance Company settled her claims for a payment of $15,000 in uninsured motorist benefits and $5,043.90 in PIP benefits. The action between Hartfiel and McLennan was settled when the parties stipulated that a $20,-483.90 judgment could be entered against McLennan, provided that Hartfiel would satisfy the judgment only from whatever liability insurance coverage McLennan had on the accident date. The settlement agreement was entered into pursuant to Miller v. Shugart, 316 N.W.2d 729 (Minn.1982). Based upon that settlement agreement, judgment was entered in favor of Hartfiel on October 17, 1984.

Hartfiel commenced the present garnishment action by serving a garnishment summons and disclosure form upon MSI on May 15,1986. The supplemental complaint in garnishment, pursuant to Minn.Stat. § 571.51, was served on August 25, 1986. The purpose of this action is to contest MSI’s denial of liability coverage and collect the money judgment. The supplemental complaint alleges that Agricultural Insurance Company is subrogated to any claim of its insured against Terry McLen-nan or MSI Insurance Company.

MSI interposed an answer to the supplemental complaint alleging two defenses: that Hartfiel’s claim was barred by the statue of limitations and that no coverage existed for McLennan because of a failure to give timely notice. The district court, on Hartfiel’s motion for partial summary judgment, had these two defense stricken from appellant’s answer on the grounds that appellant had wrongfully denied coverage to McLennan. Hartfiel then moved for summary judgment on the balance of her claim against MSI, asking the court to declare the settlement to be reasonable. The trial court denied this motion. Appellant and respondent then entered into a stipulation for entry of judgment. This appeal and notice of review followed.

ISSUES

I. May an insurance company assert defenses in an action brought by an injured party and her insurance company for sub-rogation?

II. Did the trial court err in denying summary judgment as to the reasonableness of the stipulated settlement?

ANALYSIS

On appeal from a summary judgment, the appellate court determines whether any genuine issue of material fact exists and whether the trial court erred in its application of the law. Betlach v. Wayzata Condominium, 281 N.W.2d 328, 330 (Minn.1979).

I.

MSI interposed two defenses in its answer to the supplemental complaint. These two defenses were stricken by the trial court on the basis that Minn.Stat. § 65B.49, subd. 3(3) (1986) makes the insurer’s liabili[218]*218ty absolute whenever injury or damage occurs. Minn.Stat. § 65B.49, subd. 3 provides:

(3) Every plan of reparation security shall be subject to the following provisions which need not be contained therein:
(a) The liability of the reparation ob-ligor with respect to the residual liability coverage required by this clause shall become absolute whenever injury or damage occurs; such liability may not be cancelled or annulled by any agreement between the reparation obligor and the insured after the occurrence of the injury or damage; no statement made by the insured or on the insured’s behalf and no violation of said policy shall defeat or void said policy.

(emphasis added).

MSI argues that this statute applies only when the real party in interest is the injured. MSI claims that the real party in interest is not Hartfiel, but is Hartfiel’s insurance company, on the basis of the supplemental complaint which states, “Agricultural Insurance Company is subrogat-ed to any claim of its insured against Terry McLennan or MSI Insurance Company.”

This court has stated that section 65B.49 can only be invoked for the benefit of accident victims and not for insurance companies seeking to avoid their contractual liabilities. See Transamerican Insurance Company v. Austin Farm Center, Inc., 354 N.W.2d 503, 507 (Minn.Ct.App.1984), pet. for rev. denied (Minn. Feb. 6, 1985). In Transamerican, this court held that when the injured has been compensated, the purpose of the applicable insurance law is satisfied. Once the injured party was compensated, the question of which insurance company should ultimately bear the burden of loss had to be resolved according to the terms of the insurance policies involved. Id.

The supreme court made a similar decision when interpreting the predecessor statute, Minn.Stat. § 170.40, subd. 6(1) (1972). The supreme court held that the Minnesota Safety Responsibility Act, whose purpose was to assure that members of the traveling public are compensated for injuries, should be liberally construed to effect that legislative aim. Leppla v. American Family Insurance Group, 306 Minn. 478, 238 N.W.2d 592, 595 (1976). However, the statute is remedial only in favor of an injured third person, and the statute should not provide a defense when the injured party has been compensated and it is an insurance company seeking payment. See id.

In Leppla, American Family denied liability coverage to its insured on the basis that its insured failed to comply with policy provisions. The insured then stipulated to entry of judgment of $10,000 against him if the plaintiff looked to the defendant’s insurer for payment. Plaintiff then collected $19,000 in uninsured motorist benefits and agreed to reimburse its insurance carrier out of any recovery. Id. 238 N.W.2d at 593. Plaintiff then sued American Family to enforce the policy and collect the judgment.

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Hartfiel v. McLennan
430 N.W.2d 215 (Court of Appeals of Minnesota, 1988)

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Bluebook (online)
430 N.W.2d 215, 1988 Minn. App. LEXIS 971, 1988 WL 58695, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hartfiel-v-mclennan-minnctapp-1988.