M.H. and J.L.H. v. Caritas Family Services

M.H. and J.L.H. (plaintiffs), a married couple, adopted an infant boy, C.H., from Caritas Family Services (Caritas) (defendant), a Catholic social-service agency. Caritas informed the plaintiffs that C.H. had some history of incest in his background. As C.H. grew older, the plaintiffs witnessed serious behavioral and emotional problems and requested information regarding C.H.’s genetic background as part of his ongoing medical treatment and therapy. Caritas provided the plaintiffs with a document stating that C.H.’s parents were siblings. Caritas also disclosed that C.H.’s father was in good health but was hyperactive and had low intelligence and mental-health issues. The plaintiffs filed suit against Caritas, asserting claims of intentional and negligent misrepresentation. Specifically, the plaintiffs claimed that Caritas had known but failed to disclose the relationship and medical histories of C.H.’s genetic parents. Caritas moved for summary judgment. The plaintiffs amended their complaint to add allegations of intentional and negligent infliction of emotional distress and a claim for punitive damages. The trial court granted Caritas’s motion for summary judgment intentional misrepresentation and emotional distress claims but denied summary judgment as to the negligent-misrepresentation claim. The plaintiffs appealed. The appellate court reversed. The Supreme Court of Minnesota granted certiorari to review.