Friday, April 8, 2011
A Bridge Too Far?: Court Finds Car Crash On "Wisconsin Side" of MN/WI Bridge Supported Personal Jurisdiction in Minnesota
From my childhood, I remember the classic brain teaser, "If a plane crashes on the border between Canada and the Unites States, where do they bury the survivors?" This brain teaser was the first thing that came to my mind when I read the opinion of the Court of Appeals of Minnesota in Christian v. Birch, 763 N.W.2d (Minn.App. 2009), which raised the following question: "If cars crash on the bridge between Minnesota and Wisconsin, where do they hold the trial?" And, according to the court, the answer can be Minnesota, even if the crash is on the "Wisconsin side" of the bridge.
In Birch, a vehicle driven by Judith M. Birch, a Wisconsin resident, collided head-on with a vehicle driven by Genna L. Christian, a Minnesota resident. The collision occurred on the Blatnik Bridge, which spans the St. Louis River between Superior, Wisconsin and Duluth, Minnesota. Christian was driving toward Wisconsin while Birch, who was intoxicated, was driving toward Minnesota, but in the Wisconsin-bound lane. It was undisputed that the accident occurred only feet from what is commonly referred to as the "arch" or center of the bridge. There is a white line at the center of the bridge, and the accident occurred on the "Wisconsin side" of the bridge.
Christian thereafter brought a negligence action against Birch in Minnesota state court, and the trial court found that it lacked personal jurisdiction over Birch because it treated the white line as the boundary between Minnesota and Wisconsin, and there was no evidence of other contacts between Birch and Minnesota. Subsequently, Christian appealed, and the Court of Appeals of Minnesota reversed. It first found that there was "no evidence in the record...to support a conclusion that the "white line" is a legally recognized boundary between Minnesota and Wisconsin."
Moreover, the court found that even if the white line were the legal boundary, this fact would be irrelevant because "Minnesota courts...have concurrent jurisdiction over events that occur on bridges spanning boundary waters" pursuant to Minn.Stat. Section 484.02, which provides that
For the purposes of exercising the concurrent jurisdiction of the courts of this state in civil and criminal cases arising upon rivers or other waters which constitute a common boundary to this and any adjoining state, the counties bordering upon such waters shall be deemed to include so much of the area thereof as would be included if the boundary lines of such counties were produced in the direction of their approach and extended to the opposite shore.
Thus, because the collision occurred on a bridge spanning a boundary water, Minnesota's long-arm statute, Minn.Stat. § 543.19, was satisfied because Birch "'commit[ed] an act in Minnesota causing injury or property damage.'" Because the court also found that Minnesota's exercise of personal jurisdiction would be consistent with federal due process, it reversed the trial court's ruling.