Legal Memorandum: Elements of a Negligence Case in MN

Issue: Under Minnesota law, what is required to establish an event was a substantial contributing factor to an injury?

Area of Law: Personal Injury & Negligence
Keywords: Proximate cause; Substantial factor; Cause of injury
Jurisdiction: Minnesota
Cited Cases: 539 N.W.2d 398
Cited Statutes: None
Date: 04/01/2013


Proximate cause is a necessary element in every negligence case; however, whether a particular incident is the proximate cause of Plaintiff’s injury is ordinarily a question of fact for the jury.  Lubbers v. Anderson, 539 N.W.2d 398, 402 (Minn. 1995).  Only when “reasonable minds could reach only one conclusion, is the existence of proximate cause a question of law.”  Id.  See Osbourne v. Twin Town Bowl, 749 N.W.2d 367, 372 (Minn. 2008) (“we long ago defined a proximate cause of a given result as ‘a material element or a substantial factor in the happening of that result.'”).  Generally, a given event need not be the sole cause of injury to be a proximate cause; it is enough “if it is a co-operating, concurring, or proximately contributing cause.”  Osbourne, 749 N.W.2d at 373 n.3; see also Sosa v Alvarez-Machain, 542 U.S. 692, 704 (2004) (“Proximate cause is causation substantial enough and close enough to the harm to be recognized by law, but a given proximate cause need not be, and frequently is not, the exclusive proximate cause of harm.”).


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