Minnesota Court of Appeals: Wrongful Death Claim Expired Before Death

A decision by the Minnesota Court of Appeals last month ended questions surrounding the statute of limitations in a wrongful death claim involving a defective mechanical heart valve implanted in a patient in 1988. The patient died in 2007 after the failure of the device, and the man's wife subsequently sued the manufacturer of the heart value for damages for wrongful death.

The manufacturer claimed that the Minnesota statute of limitations for wrongful death in the case expired six years after doctors implanted the device in the patient. At first glance, the argument might seem preposterous because it bars a wrongful death claim seven years before the death of the patient. A closer review of the law and the legislature's intent in passing it adds credibility to the manufacturer's position.

Interpreting the language of the statute of limitations

The Minnesota statute of limitations law states that a wrongful death action "may be commenced within three years after the date of death provided that the action must be commenced within six years after the act or omission." According to the Court of Appeals, the legislative intent was to limit wrongful death claims to a maximum of six years after the act or omission. The act or omission in this case happened in 1988, when doctors implanted the heart valve into the patient and not in 2007 when the patient died.

The Purpose and effect of application of the statute of limitations

Statutes of limitations prevent people from delaying filing claims while memories fade and witnesses and evidence disappear. The law favors resolving conflicts within a reasonable time even where the application of the statute of limitations in particular cases might appear to produce a harsh result.

In this case, the widow lost her husband and lost the right to compensation from the negligent party for such things as:

  • Lost financial contributions her spouse might have made
  • Lost care, comfort and society of her deceased spouse
  • Reimbursement for medical expenses for the care and treatment of the deceased
  • Funeral expenses and burial service fees

Protecting yourself from statute of limitations problems

Different types of cases have different statutes of limitations. Sometimes, as in this wrongful death case, the interpretation and application of the statute of limitations can lead to an unusual result that bars a cause of action based upon a person's death seven years before the person dies.

If you or a loved one are injured through the negligent conduct of another party, consulting with a personal injury attorney as soon possible after the claim arises might help to avoid running afoul of the statute of limitations.