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Keywords

settlementplaintiffdefendantcivil procedure
settlementdefendantsustainedcivil procedure

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Spaulding v. Zimmerman, 263 Minn. 346, 116 N.W.2d 704

Facts

David Spaulding, a minor, was involved in an automobile accident on August 24, 1956, which resulted in severe injuries. A settlement of $6,500 was reached on March 5, 1957, without knowledge of an aorta aneurysm that may have been caused by the accident. This condition was known to the defendants and their counsel but was not disclosed to the court or to David and his family at the time of the settlement approval. After discovering the aneurysm in 1959, David sought to vacate the settlement.

The prior action was brought against defendants by Theodore Spaulding, as father and natural guardian of David Spaulding, for injuries sustained by David in an automobile accident, arising out of a collision which occurred August 24, 1956, between an automobile driven by John Zimmerman, in which David was a passenger, and one owned by John Ledermann and driven by Florian Ledermann.

Issue

Did the District Court abuse its discretion in vacating the settlement approved on behalf of the minor when it was later revealed that the minor was suffering from an undisclosed aorta aneurysm potentially related to the accident?

Did the District Court abuse its discretion in vacating the settlement approved on behalf of the minor when it was later revealed that the minor was suffering from an undisclosed aorta aneurysm potentially related to the accident?

Rule

The court may vacate a settlement approved on behalf of a minor if it is shown that the court was unaware of distinct and separate injuries at the time of approval, and that one party had knowledge of these injuries while the other did not.

The court may vacate a settlement approved on behalf of a minor if it is shown that the court was unaware of distinct and separate injuries at the time of approval, and that one party had knowledge of these injuries while the other did not.

Analysis

The court applied Rule 60.02(6) of the Rules of Civil Procedure, determining that the defendants' failure to disclose the aorta aneurysm constituted a significant oversight that warranted vacating the settlement. The court noted that the defendants were aware of the aneurysm's existence and its potential seriousness, which was not disclosed to the court or the plaintiff. This lack of disclosure was deemed to have resulted in an unconscionable advantage for the defendants.

The court applied Rule 60.02(6) of the Rules of Civil Procedure, determining that the defendants' failure to disclose the aorta aneurysm constituted a significant oversight that warranted vacating the settlement.

Conclusion

The Supreme Court affirmed the District Court's decision to vacate the settlement, concluding that the court did not abuse its discretion given the circumstances surrounding the undisclosed injury.

The Supreme Court affirmed the District Court's decision to vacate the settlement, concluding that the court did not abuse its discretion given the circumstances surrounding the undisclosed injury.

Who won?

David Spaulding prevailed in the case because the court found that the defendants' concealment of the aorta aneurysm justified vacating the settlement.

David Spaulding prevailed in the case because the court found that the defendants' concealment of the aorta aneurysm justified vacating the settlement.

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