Hartridge v. State Farm Mut. Auto. Ins. Co.

271 N.W.2d 598



Intention is an essential element of a claim for damages sustained as a result of contractual interference.


Appellant assignee was a doctor at a medical clinic when he was involved in a motor vehicle accident. As a result of a negligence action against the driver and his insurer, the doctor assignee was awarded damages that included an award for loss of earnings. The medical clinic assigned any claim it had against the driver and his insurer as a result of the accident to the assignee. The doctor assignee then brought an action to recover for lost profits of the medical clinic. The trial court granted the insurer's motion to dismiss. On appeal, the doctor assignee argued that the clinic, as master or employer, had a right at common law to maintain an action against a tortfeasor for damages sustained on account of loss of services for the injuries he sustained as a servant or employee.


Does an employer have a claim for relief for loss of earnings suffered by it due to a negligent injury to its employee?




The judgment dismissing the assignee's action for lost profits of an employer medical clinic was affirmed. The appellate court held that while tort law allowed actions for negligent interference with certain familial relational interests, the modern relation between employer and employee, which is no longer a quasi-familial one, should not be honored with such protection. Further, public policy grounds weighed heavily against allowing recovery by an employer for negligent injury of his employee.

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