Olson v. Costello
In a wrongful death suit brought by the estate of a Minnesota Twins prospect, the trial court denied the defendant physician's motion for summary judgment on workers' compensation immunity under Minnesota law (finding fact issues), then sua sponte under Rule 1.510(f)(3) granted summary judgment determining Florida law governed, which defeated the immunity defense because Florida's Act excludes professional athletes. The Sixth DCA dismissed the appeal of the denial order for lack of jurisdiction under Hastings/Reeves, but held it had jurisdiction over the affirmative grant of summary judgment even though it lacked 'magic words,' and affirmed the choice-of-law ruling under the significant relationships test.
Key facts
- Estate of a Minnesota Twins prospect brought a wrongful death suit against a physician defendant in Florida.
- The trial court initially denied the defendant's summary judgment motion on workers' compensation immunity, finding factual issues existed, then sua sponte granted summary judgment determining Florida law applied instead of Minnesota law.
- +2 more key facts with a free trial
Why it matters
This decision draws a clear line in the workers' compensation immunity appeal landscape: the Hastings/Reeves 'magic words' rule bars appeals from denials of summary judgment, but not from affirmative grants of summary… — full analysis with a trial
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