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Eischen v. Crystal Valley Cooperative
Citations: 835 N.W.2d 629; 2013 Minn. App. LEXIS 76; 2013 WL 3968775Docket: No. A13-0104
Court: Court of Appeals of Minnesota; August 5, 2013; Minnesota; State Appellate Court
Appellants Kurt and JoAnn Eischen sued respondent Crystal Valley Cooperative, claiming negligence led to Kurt's injuries on July 1, 2010, resulting in pain, disfigurement, disability, and JoAnn's loss of companionship. The Eischens attributed the injuries to Crystal Valley's negligent training and supervision of employees, and the provision of chains used to tow a sprayer on their farm. Crystal Valley defended itself by invoking the primary assumption of risk doctrine and filed a third-party claim against Dan Eischen, alleging his negligent tractor operation contributed to the injuries. Kurt Eischen, an experienced farmer managing 1,120 acres with his sons, had contracted Crystal Valley for fertilization. On the incident date, Crystal Valley sent employees and a 30,000-pound liquid-fertilizer sprayer to his farm, which became stuck twice. After the first incident, the Eischens provided a tractor and tow rope while Crystal Valley supplied two 3/8-inch chains. During the second attempt to free the sprayer, a chain snapped and struck Kurt, causing significant injuries that required extensive medical treatment. There are disputes regarding the circumstances of the incident, including Kurt’s position when signaling Dan to move the tractor, the speed of the tractor’s movement, and the condition of the chains provided by Crystal Valley. The district court's dismissal of the Eischens' negligence claim on summary judgment was reversed, and the case is remanded for trial. Crystal Valley sought summary judgment, arguing that Kurt Eischen primarily assumed the risk of his injuries, leading the district court to grant the motion and dismiss Eischen's negligence claim. The appeal questions whether the district court correctly applied the primary-assumption-of-risk doctrine to bar Eischen's claim. Appellate review is de novo, assessing if genuine issues of material fact exist and whether the law was properly applied, viewing evidence favorably for the party against whom summary judgment was granted. Crystal Valley's defense rests on the assertion that Eischen's primary assumption of risk absolves them of any duty of care. The doctrine negates negligence by eliminating the defendant's duty to the plaintiff. Typically, whether a plaintiff has knowledge sufficient for assumption of risk is determined by a jury, particularly if conflicting evidence exists. Previous rulings indicate that assumption of risk is a jury question unless the facts are undisputed and lead to one reasonable conclusion. To establish negligence, a plaintiff must demonstrate duty of care, breach, injury, and causation. The district court determined that primary assumption of risk applied to the accident's cause, defining it as a scenario where a plaintiff knowingly encounters a hazard. The court noted that this doctrine is rarely used in Minnesota for summary judgment in negligence claims and is often limited to inherent risks in activities like sports. The court likened the circumstances of Eischen, a farmer accustomed to handling farm activities, to such activities. Although the court did not explicitly analyze whether Crystal Valley owed Eischen a duty of care, it implied such a duty existed, citing insufficient evidence from Eischen regarding Crystal Valley's alleged failure in reasonable care. Eischen's complaint claimed that Crystal Valley had a duty in the training and supervision of its employees and the adequacy of the chains used for the task. Eischen also asserted in their brief that it is undisputed Crystal Valley owed him a duty of reasonable care. Eischens opposed summary judgment by submitting an affidavit from an agricultural-safety expert, who criticized Crystal Valley for failing to properly train employees on safety procedures related to a stuck sprayer incident. The expert noted that Crystal Valley should have instructed employees on the proper handling of towing equipment, maintained a safe distance during operations, and implemented safety measures to prevent injury from potential equipment failure. However, Eischens did not provide a legal basis for Crystal Valley's duty towards Kurt Eischen in the district court or on appeal. Crystal Valley claimed that Kurt Eischen consented to relieve it of any duty owed. On appeal, the company focused its argument on Eischen's primary assumption of risk rather than disputing the existence of a duty. A reviewing court is generally limited to issues presented in the trial court, creating uncertainty about whether the district court appropriately assessed Crystal Valley's duty to Kurt Eischen before considering primary assumption of risk. It is established that a court must first determine whether a duty existed before addressing assumption of risk, as a lack of duty would preclude submitting a negligence claim to a jury. Minnesota law does not recognize negligent training as a cause of action, but contractors owe a duty of care to perform their contractual obligations without causing harm. Additionally, general negligence principles impose a duty of reasonable care when a defendant's actions foreseeably risk injury to another. Negligent supervision involves an employer's failure to adequately oversee employees to prevent foreseeable harm, with liability stemming from the principle of respondeat superior, which holds employers accountable for their employees' actions within the scope of employment. Crystal Valley’s plant operator testified that getting equipment unstuck is inherently risky, with towing being the most dangerous task they undertake. Typically, a farmer provides a tractor, and Crystal Valley uses either the farmer's or its own chains. Crystal Valley, hired by Kurt Eischen to spray fertilizer, had a duty to exercise due care in supervising its employees and ensuring they had safe equipment. The court examined whether the primary-assumption-of-risk doctrine negated this duty. This doctrine applies when parties voluntarily enter a relationship where the plaintiff assumes known incidental risks, relieving the defendant of a duty of care if injuries arise from those risks. The application of this doctrine requires the plaintiff’s consent to relieve the defendant of duty and is not contingent on the reasonableness of that consent. It is specifically applicable in limited circumstances, such as inherently dangerous sporting events, and is rarely found in Minnesota law. In this case, the district court noted that Kurt Eischen, by positioning himself between the sprayer and tractor while managing the tow rope, should have been aware of potential dangers, including the possibility of the chain or rope breaking. Despite this knowledge, Eischen chose to place himself in a risky position. The challenge to the district court’s ruling rested on the claim that Eischen did not fully recognize the dangers of his actions. For the primary-assumption-of-risk doctrine to apply, the plaintiff must possess actual knowledge of the specific risk, not just general awareness. The evidence regarding Eischen's actual knowledge of the risks associated with the chains provided by Crystal Valley was unclear and disputed. A reasonable fact-finder could deduce that Kurt Eischen was unaware of the specific risks involved in assisting Crystal Valley with a sprayer when he positioned himself between the tractor and sprayer and signaled for the tractor to move. In resolving conflicting inferences, the court favors the appellants. Crystal Valley contends that farming, particularly involving tractors, is more dangerous than sports events where the primary assumption of risk doctrine typically applies. However, the court cannot consider statistical evidence provided solely through unverified website links, as these were not part of the court record. While evidence indicates that towing stuck farm equipment is dangerous, the court determines that it does not fall under the primary-assumption-of-risk doctrine because the risks can be avoided through recognized safety procedures, as noted by Eischen’s agricultural-safety expert. For negligence claims, it is essential to establish a duty of care, a breach of that duty, and a direct causation of injury. Generally, questions of breach and causation are factual, not legal, and summary judgment is rare in negligence cases. The court finds that genuine issues of material fact exist regarding whether Crystal Valley breached its duty to Eischen and whether that breach caused his injuries. Therefore, the district court's application of the primary-assumption-of-risk doctrine to dismiss Eischen’s negligence claim was erroneous, leading to a reversal and remand for trial. Dan Eischen did not participate in the summary-judgment hearing but supported Kurt Eischen's negligence claim in his response to Crystal Valley’s third-party complaint.