Klingbeil v. Ramfjord, et. al.

(Unpublished, No. A15–1215)

Minnesota Court of Appeals, March 14, 2016

 

The appellate court in Klingbeil v. Ramfjord held that the owner of a vehicle cannot be held vicariously liable for the negligent driving of a co-owner of that vehicle.

Krystal and Peter Ramfjord are relatives and co-owners of a motor vehicle.  Krystal Ramfjord was driving the vehicle and was involved in a collision with Mr. Enoch Klingbeil’s vehicle on July 8, 2008.  Mr. Klingbeil sued the Ramfjords for negligence.  Klingbeil alleged that Peter was vicariously liable for Krystal’s negligence because she was driving the vehicle with Peter’s permission.  Klingbeil attempted service of the summons and complaint on both defendants.  The complaint was served on Peter, but he told the process server that Krystal did not reside there.  The Ramfjords answered the complaint alleging insufficient service of process.

Nine months later, the Ramfjords moved for summary judgment, claiming that Krystal was never properly served and that Peter could not be held vicariously liable because Krystal was a co-owner of the vehicle.  Klingbeil conceded to the district court that Krystal was not properly served, but argued that disputed material facts precluded summary judgment.  The district court granted the Ramfjords’ motion for summary judgment and dismissed the claims against both defendants.  Klingbeil appealed.

The appellate court first held that it was undisputed that Klingbeil’s service of process on Krystal was defective and, as such, the district court properly granted summary judgment as to Klingbeil’s claims against Krystal.

The court next turned to whether Peter could be held to be vicariously liable for Kystal’s negligence.  The court looked to the Minnesota Safety Responsibility Act (The Act), which states that “Driver deemed agent of owner. Whenever any motor vehicle shall be operated within this state, by any person other than the owner, with the consent of the owner, express or implied, the operator thereof shall in case of accident, be deemed the agent of the owner of such motor vehicle in the operation thereof.”

Pursuant to The Act, the owner of a vehicle is typically vicariously liable for the negligence of someone who is operating the owner’s vehicle with their consent.  However, the driver must be “any person other than the owner.”  This is the language that the court analyzed in this case.  The court cited Ridler, 565 N.W.2d at 39, which held that a husband could not be held liable for the negligent driving of his wife where the husband and wife co-owned the vehicle together, because the driver was not someone “other than the owner.”  The court followed the holding in Ridler and determined that Peter and Krystal were co-owners of the vehicle and, as such, Peter could not be vicariously liable for Krystal’s negligence.

 

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