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Blatz v. Allina Health System
Minnesota Court of Appeals
622 N.W.2d 376 (2001)
Mary Blatz (plaintiff) awoke one morning having trouble breathing and with pain in her chest. Blatz’s husband called 911. The dispatcher notified the sheriff’s office and the ambulance service, which was owned by Allina Health System (Allina) (defendant). The sheriff’s deputy arrived at Blatz’s home and began administering CPR. The paramedics had difficulty finding Blatz’s home and arrived five or six minutes after the deputy. By then, Blatz was not breathing and had no pulse. The paramedics immediately gave Blatz oxygen, and within about three minutes, her heart was pumping again. Blatz was in a coma for four weeks. Blatz’s heart attack caused brain damage from lack of oxygen, leading to her permanent mental and physical impairment. Blatz sued Allina for negligence, because Allina’s paramedics reached her home late after getting lost. Blatz alleged that the paramedics’ navigational errors caused them to arrive two to five minutes later than they otherwise would have. Blatz’s expert testified that those two to five minutes were the crucial window within which Blatz might have avoided brain damage had she been resuscitated. Allina’s experts testified that Blatz’s brain damage occurred before the arrival of the sheriff’s deputy, making the paramedics’ delay inconsequential. The judge instructed the jury to hold Allina liable only for damages caused by Allina’s negligence, not for damages caused by Blatz’s heart attack. The judge further instructed the jury that if it could not separate out the damages from the two sources, Allina should be held liable for all the damages. The jury found in favor of Blatz, awarding $11 million in damages. Allina appealed, challenging, among other things, the judge’s instruction to the jury on damages.
Rule of Law
Holding and Reasoning (Lansing, J.)
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