Jurisdiction/Choice-Of-Law
Drunken Defendant collided head-on with a vehicle driven by Plaintiff on the Blatnik Bridge, which spans the St. Louis River between Superior, Wisconsin and Duluth, Minnesota.
Plaintiff was driving toward Wisconsin; Defendant “was driving toward Minnesota, but in the Wisconsin-bound lane,” as the Court of Appeals put it. (I favor compass directions and the clarity of “the wrong side of the road,” myself.) The accident occurred only feet from what is commonly referred to as the arch or center of the bridge directly above the St. Louis River. Minnesota emergency vehicles responded to the collision scene and transported Plaintiff to a medical facility in Minnesota, where she received medical care. Wisconsin police officers also responded to the scene. The Wisconsin officers arrested Defendant for driving while intoxicated. Criminal charges were subsequently filed against Defendant in Wisconsin, and she pleaded guilty to a charge of causing injury by intoxicated use of a motor vehicle. Both Plaintiff and Defendant are Wisconsin residents. Plaintiff had a passenger in her vehicle at the time of the collision, a Minnesota resident. Defendant does not own any property in Minnesota and is not employed in Minnesota.
The accident happened more than three years prior to the filing of the complaint and less than six years. The applicable statutes of limitation for the negligence claim are three years (Wisconsin) and six years (Minnesota).
The district court concluded that Minnesota has subject-matter jurisdiction, but determined that Wisconsin’s three-year statute of limitations barred Plaintiff’s lawsuit and that Plaintiff had therefore failed to state a claim for which relief could be granted. The district court also concluded that Minnesota lacked personal jurisdiction over Defendant. The district court granted summary judgment for Defendant on both grounds.
You are the Court of Appeals. Do you affirm or reverse and why? You have twenty minutes for this question (click here to link to appellate decision).