Reed v. University of North Dakota

Citations: 543 N.W.2d 106; 1996 Minn. App. LEXIS 103; 1996 WL 33066Docket: C5-95-1357

Court: Court of Appeals of Minnesota; January 30, 1996; Minnesota; State Appellate Court

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Jace Reed appeals the dismissal of his personal injury claims against University of North Dakota (UND) Coaches John Gasparini and James Scanlan, as well as personal injury and contract claims against UND itself. Reed was recruited by UND in 1989 and suffered severe dehydration during a 10-kilometer charity race in 1991, leading to significant medical expenses. He initially filed a lawsuit in North Dakota Federal District Court but later voluntarily dismissed it. Subsequently, he filed a personal injury suit in Minnesota against the same defendants, including the North Dakota Association for the Disabled (NDAD). The Minnesota district court dismissed NDAD for lack of personal jurisdiction but allowed Reed to conduct discovery on immunity, jurisdiction, and choice of law issues related to the remaining defendants. 

In January 1995, the defendants renewed their motions to dismiss based on several grounds, including lack of jurisdiction and sovereign immunity. The district court dismissed claims against Gasparini and Scanlan on forum non conveniens grounds and those against Perry, Peterson, and UND for lack of personal jurisdiction. Reed's appeal raises three primary issues: the applicability of North Dakota law, the jurisdiction of Minnesota courts over UND for injuries occurring in North Dakota, and the legal viability of Reed's contract claims. During oral arguments, Reed clarified that he is suing Gasparini and Scanlan solely in their roles as coaches for UND, indicating that liability falls under the principles of agency law.

The district court dismissed personal injury claims against the University of North Dakota (UND) for lack of personal jurisdiction and against Gasparini and Scanlan based on forum non conveniens. However, there are significant policy reasons to evaluate the dismissals using alternative grounds of choice of law and comity. The court determined that North Dakota law governs this case, a conclusion that aligns with the analysis of conflicting laws between North Dakota and Minnesota regarding sovereign immunity. North Dakota abolished sovereign immunity for tort liability in 1994, while Minnesota did so much earlier. Since the claims arose before North Dakota's change, a conflict exists regarding sovereign immunity.

The choice of law analysis involves assessing whether there are sufficient contacts with a state to apply its law constitutionally. Minnesota's criteria for sufficient contacts, derived from U.S. Supreme Court precedent, indicate that significant contacts must exist to avoid arbitrary or unfair law application. Although UND has extensive contacts with Minnesota, they are unrelated to Reed's claims which arose in North Dakota, making Minnesota law potentially arbitrary.

The analysis further examines the Milkovich factors, which support applying North Dakota law. The second factor, maintenance of interstate order, strongly favors North Dakota law, as applying Minnesota law would disrespect North Dakota's sovereignty and suggest forum shopping by Reed, which is disfavored in Minnesota. The third Milkovich factor, simplification of the judicial task, also supports North Dakota law, as applying Minnesota's sovereign immunity would complicate judgments against North Dakota's sovereign. Additionally, UND asserts discretionary immunity as a defense, reinforcing the rationale for applying North Dakota law.

The application of Minnesota law regarding discretionary immunity to North Dakota's sovereign actions poses challenges. The fourth Milkovich factor emphasizes the importance of the forum's governmental interest; while Minnesota prioritizes compensating tort victims, maintaining interstate order may take precedence. The fifth factor assesses which forum has a superior legal framework, with Minnesota's rules on sovereign immunity considered better, particularly following North Dakota's recent legal adjustments to align with Minnesota's. However, this factor is only relevant if the preceding factors do not decisively indicate a conclusion. In this case, the analysis of the other factors leads to the determination that North Dakota law governs. Consequently, the district court's ruling that North Dakota law applies is upheld.

The district court dismissed personal injury claims against the University of North Dakota (UND) for lack of personal jurisdiction and against Gasparini and Scanlan based on forum non conveniens. The dismissal was deemed appropriate under the doctrine of comity, making it unnecessary to evaluate other potential justifications for the dismissal. The comity doctrine requires careful consideration to avoid disrupting the jurisdiction of foreign courts and has been recognized by various courts to honor another state's sovereign immunity. The U.S. Supreme Court has ruled that while a forum is not constitutionally obligated to recognize another state's sovereign immunity, it may do so voluntarily as a matter of comity. In context, the Supreme Court's decision in Nevada v. Hall allowed California to assert jurisdiction over Nevada for an accident involving a Nevada state employee, highlighting that California had a more significant interest in adjudicating the matter than Nevada. In contrast, the current case involves plaintiffs suing North Dakota in a Minnesota court for events that transpired in North Dakota, indicating that Minnesota has a lesser interest in providing a forum.

The strong dissent in Nevada v. Hall and the majority opinion suggest that had the accident occurred in Nevada, the Supreme Court might have reached a different conclusion. Minnesota's interest is diminished because North Dakota law governs the case. The Supreme Court has emphasized the importance of resolving local controversies in their home jurisdiction and the appropriateness of applying state law in that forum, as seen in Gulf Oil Corp v. Gilbert. 

Reed's attempt to bring North Dakota's sovereign into a Minnesota court to apply Minnesota law to negligence claims arising in North Dakota raises issues regarding interstate relations and challenges North Dakota's sovereignty, particularly since North Dakota law recognized the sovereign immunity of the University of North Dakota (UND) and its agents at the time of Reed's injury. Consequently, Minnesota courts should refrain from asserting jurisdiction in this case as a matter of comity, leading to the affirmation of the district court's dismissal of Reed's personal injury claims.

Regarding Reed's claims of breach of either an oral or written contract with UND, the court determined these claims fail legally. The district court reviewed the contract claims under a summary judgment standard due to the introduction of matters outside the pleadings. Reed has not identified any specific contractual breach despite opportunities to do so. He speculates about a general duty of colleges to protect athlete health but fails to link this duty to a contractual obligation. Even assuming the National Letter of Intent constitutes a written contract, Reed does not allege any breach of its provisions, which only stipulate financial aid in exchange for playing hockey, with no obligations regarding medical care. Thus, the district court correctly found that Reed's contract claims fail as a matter of law. The decision is affirmed, noting that North Dakota law governs the case and that Minnesota courts should not exercise jurisdiction.