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Background: Minnesota Court of Appeals (Google Maps). Inset: Jason Melvin Niebuhr (Legacy Remembers).
The Minnesota Court of Appeals ruled Monday that the parents of a 17-year-old driver can be held liable in a wrongful-death lawsuit for the crash that killed the boy’s boss, a blind man who was riding in the car as a passenger. The case raised a tricky procedural question about whether immunity under workers’ compensation law extends to someone who might be vicariously liable for an employee’s negligence.
Jason Niebuhr, 39 years old at the time of his death, was the founder and sole owner of Wells Computer and Electronics, Inc., a company that repaired, sold, and installed various electronic equipment. Though Niebuhr was blind, he specialized in electronics repair and installation, and serviced many customers through his business.
Wells employed a handful of employees, including Jacob Sieberg. The employees primarily assisted Niebuhr. Wells maintained workers’ compensation insurance for its employees, but not for Niebuhr himself as an owner.
Sieberg worked at Wells during his junior year of high school, and his duties included helping install and repair equipment and driving Jason to and from customers’ homes — usually using the company vehicle. According to the court record, Sieberg occasionally used a personal truck owned by his parents for work purposes. Sieberg’s parents purchased the truck for their son’s use, and Sieberg used it to travel to and from school and work.
On one occasion when the company vehicle was otherwise in use, Sieberg used his personal truck to drive Niebuhr to make a delivery. While driving, Sieberg lost control of the truck, causing it to spin into a ditch on the highway and roll four times. Niebuhr, who had been sitting in the passenger seat, died at the scene of the accident.
Rebecca Niebuhr, Jason’s mother, brought a wrongful death action for $50,000 against Jacob Sieberg and his parents, Timothy and Michele Sieberg. The district court ruled that Jacob Sieberg was entitled to co-employee immunity from the lawsuit under workers’ compensation law, which prohibits lawsuits against coworkers for injuries. The district court also ruled that Timothy and Michele Sieberg were to be dropped as defendants, reasoning that if Jacob was immune, then his parents cannot be vicariously liable for his actions.
The Minnesota Court of Appeals, however, disagreed about Jacob’s parents, and ruled that state law should “be read broadly in favor of affording relief to injured or deceased victims,” and that vehicle owners may be held vicariously liable for the actions of those driving their vehicles.
The 16-page opinion, authored by Judge Elizabeth Bentley and signed by Judges Renee Worke and Michael Kirk, cited a 1936 Minnesota Supreme Court decision and concluded that although Jacob himself is shielded from liability under workers’ compensation law, his parents are not.
Michelle Kuhl, the attorney representing the Siebergs, said, “We disagree with the decision and we’re still analyzing our options.”
Counsel for Niebuhr did not immediately respond to request for comment.
You can read the full opinion here.
