Ignoring Previously Used Case Law

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Here’s an analysis of the situation based on your question:

⚖️ Core Issue:

The Plaintiff’s sworn declaration points out that:

• Judge Miller, in his June 16, 2023, Summary Judgment Order (Doc. 429), claimed “Plaintiffs cite no case, in this or any other jurisdiction, where an emotional distress claim was sustained based on such a theory, and the Court discovers none.” (p. 28).
• However, Plaintiffs had cited Cafferty v. Garcia’s of Scottsdale, Inc., 375 N.W.2d 850 (Minn. 1985) four times in their summary judgment memorandum (Doc. 394, pp. 39-40, 42).
• Cafferty is a Minnesota case directly supporting the Plaintiff’s IIED theory based on the “actor’s knowledge” of a plaintiff’s susceptibility.
• Judge Miller even previously cited Cafferty in his December 6, 2022 Order (Doc. 366, p. 36), where he acknowledged that Marie would have to prove that Sean knew of her unique susceptibility to distress.

⚖️ Why is this Significant?

1. Cafferty’s Importance to the IIED Claim:

   • In Cafferty, the Minnesota Supreme Court allowed an IIED claim where the defendant’s conduct was outrageous because they knew the plaintiff was particularly vulnerable to emotional harm.
   • That’s the exact theory Marie Stevenson advanced: that Sean knew of Marie’s special susceptibility when he sent letters to her estranged and allegedly abusive father, [Redacted].

2. Contradiction in the Court’s Analysis:

   • By ignoring the Cafferty case (despite Plaintiffs citing it and the Judge relying on it earlier), the Court effectively mischaracterized the legal availability of the claim.
   • This mischaracterization may have materially affected the dismissal of Marie’s IIED claim at summary judgment.

3. Effect on Summary Judgment Ruling:

   • If the Court had properly considered Cafferty, it might have recognized that Marie’s IIED claim had legal precedent and was not a novel theory.
   • Consequently, Marie’s IIED claim could have survived summary judgment because a fact dispute existed as to whether Sean’s conduct was outrageous in light of his knowledge of Marie’s unique emotional vulnerability (as outlined in Cafferty).

📌 Potential Argument / Impact:

• Plaintiffs could argue that the summary judgment order was based on a clear factual error or oversight:
  • The Court claimed no legal precedent existed supporting Plaintiffs’ IIED theory when Cafferty clearly provides it.
• This could be grounds for:
  • A motion for reconsideration,
  • An appeal citing clear error,
  • Or arguing that the dismissal was premised on a misapplication of law.

🔎 Supporting Quote from December 6, 2022 Order:

In the December 2022 Order (Doc. 366, p. 36), Judge Miller directly referenced Cafferty:

“Marie would need to show that Sean’s conduct was ‘extreme and outrageous,’ that she ‘suffered severe emotional distress,’ and that Sean knew that Marie was ‘particularly susceptible to emotional distress.’”

That is straight from Cafferty’s standard.

✅ Conclusion:

The significance of the sworn declaration is high. It highlights a critical oversight undermining the Court’s reason for dismissing Marie’s IIED claim. The Cafferty precedent—already acknowledged by the Court—directly supported Plaintiffs’ legal theory.

This apparent error could provide solid footing for seeking relief, depending on procedural posture:

• Reconsideration,
• Appeal, or
• Post-judgment motion (Minn. R. Civ. P. 60.02 or similar).

In Skarsten, we reversed summary judgment for the insurer based on the resident-relative provision and cautioned “a court must not rely on selected facts in order to justify a conclusion.” 381 N.W.2d at 19. Here, the district court’s summary-judgment decision rested on “selected facts” because it ignored relevant evidence favorable to appellants’ position, drew inferences unfavorable to appellants, and failed to view the record evidence in a light favorable to appellants.

Progressive Ins. v. Abel, No. A21-1267, 2022 WL 2124869, at *5 (Minn. Ct. App. June 13, 2022)