Sedlacek v. Prussman Contracting, Inc.

941 N.W.2d 819, 2020 S.D. 18
CourtSouth Dakota Supreme Court
DecidedApril 1, 2020
Docket29054
StatusPublished
Cited by7 cases

This text of 941 N.W.2d 819 (Sedlacek v. Prussman Contracting, Inc.) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sedlacek v. Prussman Contracting, Inc., 941 N.W.2d 819, 2020 S.D. 18 (S.D. 2020).

Opinion

#29054-a-MES 2020 S.D. 18

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

DENNIS SEDLACEK, Plaintiff and Appellant,

v.

PRUSSMAN CONTRACTING, INC., Defendant and Appellee.

APPEAL FROM THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT BROOKINGS COUNTY, SOUTH DAKOTA

THE HONORABLE DAWN M. ELSHERE Judge

RENEE H. CHRISTENSEN of Johnson & Christensen Law Office, P.C. Sioux Falls, South Dakota

EDWIN E. EVANS of Evans, Haigh & Hinton, LLP Sioux Falls, South Dakota Attorneys for plaintiff and appellant.

MICHAEL L. LUCE DANA VAN BEEK PALMER of Lynn, Jackson, Shultz & Lebrun, P.C. Sioux Falls, South Dakota Attorneys for defendant and appellee.

CONSIDERED ON BRIEFS MARCH 17, 2020 OPINION FILED 04/01/20 #29054

SALTER, Justice

[¶1.] Dennis Sedlacek sought damages for injuries allegedly sustained while

repairing a crane owned by Prussman Contracting, Inc. A jury returned a general

verdict in favor of Prussman. Sedlacek appeals, arguing the court abused its

discretion when it admonished the jury not to consider testimony regarding OSHA

standards, denied a proposed jury instruction on OSHA standards, and denied

Sedlacek’s motion for a mistrial. We affirm.

Background

[¶2.] On Friday, January 30, 2015, Dennis Sedlacek was working for his

employer, Titan Machinery, repairing a crane at Prussman Contracting’s facility in

Brookings. Two Prussman employees, Vernon “Russ” Leubner and Rick Schwartz,

were assisting Sedlacek with the repair. Leubner was operating a forklift.

Sedlacek was directing the repair and told Leubner to lower the forks, back up six

feet, and put the forks on the ground. Sedlacek then turned his back to the forklift

and moved to his right to pick up a remote control that operated the crane.

Meanwhile, unknown to Sedlacek, Leubner drove the forklift forward again and

raised the forks. When Sedlacek turned back to the left, he claims his neck struck

one of the forks. Sedlacek testified that he reacted by yelling at Schwartz, who was

standing nearby. However, both Leubner and Schwartz denied that Sedlacek was

struck.

[¶3.] Sedlacek testified that he experienced pain in his neck and back. He

reported the injury to his employer by telephone and continued working. After

completing the repair, Sedlacek returned to Sioux Falls and was advised by his

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supervisor to get evaluated at Sanford Health’s occupational medicine clinic where

he was diagnosed with contusions to his neck and trapezius muscles. Sedlacek

returned to the clinic the following Monday because he experienced increasing lower

back pain over the weekend. Despite several months of physical therapy and

chiropractic treatments, Sedlacek’s pain complaints remained unresolved. He was

later diagnosed with a pinched nerve in his low back and underwent spine fusion

surgery at the L5-S1 level, incurring over $250,000 in medical expenses and missing

seven months of work.

[¶4.] Sedlacek commenced this suit against Prussman in April 2016,

alleging general negligence. Prussman denied liability and asserted contributory

negligence and assumption of the risk as affirmative defenses. Sedlacek later

amended his complaint to add claims that Prussman failed to train and supervise

its employees.

[¶5.] In response to Sedlacek’s discovery requests, Prussman produced a

certificate showing Leubner had completed the necessary training for workplace

forklift operation and was certified as compliant with the Occupational Health and

Safety Administration (OSHA) General Industry Standards on November 10,

2015—over ten months after Sedlacek’s alleged injury. Both Sedlacek and

Prussman listed Leubner’s OSHA certification on their pretrial exhibit lists.

However, Sedlacek had not alleged a violation of OSHA standards in either version

of his complaint, and he did not propose jury instructions that used OSHA

standards to define the standard of care for Leubner or Prussman.

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[¶6.] The case was tried by a jury on June 3-7, 2019. During cross-

examination, Leubner admitted that he had previously received training on OSHA

standards for operating a forklift during his Job Corps training in 2001 and 2002.

However, Leubner acknowledged he was not certified when he started his

employment with Prussman in 2011 or in 2015 when Sedlacek claims he was

injured. Leubner testified that at the time of the alleged incident he was not aware

that OSHA regulations require recertification every three years.

[¶7.] Over objections from Prussman’s counsel, the circuit court allowed

Sedlacek’s counsel to question Leubner about specific OSHA standards. The court

also overruled Prussman’s objections when Sedlacek’s counsel asked Lyle

Prussman, president of Prussman Contracting, about OSHA standards during

cross-examination.

[¶8.] On June 6—the fourth day of trial—Sedlacek submitted a brief and, for

the first time, proposed two jury instructions regarding OSHA standards. The first

proposed jury instruction read as follows:

Evidence has been introduced in this case on the subject of the Occupational Safety and Health Administration, OSHA, standards for safe operation of a forklift. OSHA standards can be considered as evidence of the standard of care that Defendant was expected to meet.

[¶9.] The second proposed instruction contained references to 29 U.S.C. §

654 and 29 C.F.R. §1910.178, the latter of which details OSHA’s compliance

standards and requirements for forklift training. 1 Prussman objected to these

1. In the argot of the OSHA regulations, forklifts are described as “powered industrial trucks.” 29 C.F.R. § 1910.178.

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additional proposed instructions due to their late submission, further arguing that

OSHA standards were not relevant since Sedlacek had not alleged a violation of

OSHA standards in his negligence claim and had not presented expert testimony

that an OSHA violation had occurred.

[¶10.] The court agreed and denied Sedlacek’s proposed jury instructions,

citing his failure to allege an OSHA violation in either his original or amended

complaint, as well as his failure to raise a potential OSHA violation until trial.

With regard to the testimony already admitted that related to OSHA standards and

Prussman’s potential violations, the court instructed the jury not to consider the

testimony and referenced a preliminary instruction regarding the possibility that

the jury might inadvertently hear improper evidence during the course of the trial. 2

The court, however, did allow Leubner’s training certificate to remain as an exhibit

for the jury to consider.

[¶11.] Sedlacek moved for a mistrial based on the court’s order to strike

testimony regarding OSHA standards, arguing severe prejudice because “now the

Court is going to tell the jury . . . they should ignore it all which confuses and leads

the jury to believe that either we did something wrong or worse yet that OSHA

doesn’t apply . . . .” The circuit court denied the motion for a mistrial, determining

Sedlacek had failed to establish his prejudice claim.

[¶12.] The final jury instructions stated the principles of general negligence,

including legal cause.

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Bluebook (online)
941 N.W.2d 819, 2020 S.D. 18, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sedlacek-v-prussman-contracting-inc-sd-2020.