Summary of Kotecki v. Cyclops Welding Corp.
Relevant Facts: Pl, Kotecki, sustained an injury when he caught his hand in the motor of an agitator which occurred while he was acting in the scope of his employment with Df, Carus. Kotecki claims the agitator was negligently designed, constructed, and installed without sufficient guarding devices for the motor and drive systems.
Legal Issue(s): Whether an employer sued as a 3rd party defendant in a products liability case, is liable for contribution in an amount greater than its statutory liability under the Workers Compensation Act?
Court’s Holding: No
Procedure: See attachment, Interlocutory appeal on 3rd party complaint. Trial ct denied Carus Motion 2 Strike Ad damnum Clause. Reversed and remanded w/ instructions.
Law or Rule(s): A defendant manufacturer sued in strict liability has a right of contribution against the employer of an injured worker, but that amount of an employer’s contribution would be limited by its workers compensation liability.
Court Rationale: [Skinner] determined that a df manuf. had a right of contribution against an employer in suit by worker. The Leg intended to codify that decision through the Contribution Act. The W.C. Act give an employer immunity from tort actions by its employees, there is no bar to a claim for contribution form that employer by a df held liable to that employee. WCA provides the Er an affirmative defense. Although a majority of jurisdictions do not allow a contribution action against an employer, from df sued in tort, by employee, the Minnesota rule strikes a balance between the competing interests. It allows the 3rd party to obtain limited contribution, but substantially preserves the employer’s interest in not paying more than its worker’s compensation liability. WCA shows an intent that the employer should only be required to pay an employee the statutory benefits. The Contribution Act requires that the employers contribute to tort judgments if they are partially responsible.
Plaintiff’s Argument: (Er) Although it is clear that an employer can be held liable for contribution to a manufacturer, the court has never stated if that amount is limited by the employer’s worker’s compensation liability.
Defendant’s Argument: (Manufacturer) A manufacturer, by law, has a right to contribution from the employer, and the amount that the employer can be required to pay is limited only be the extent of the damages that are attributable to the employer’s negligence.