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Swenson v. Waseca Mutual Insurance Co.12/10/2002 ilizes an indirect route, or a brief stop on the way to the facility acting at the scene of an emergency and protected from liability as provided by Minnesota's Good Samaritan law?
ANALYSIS
On appeal from summary judgment, this court asks two questions: (1) whether there are any genuine issues of material fact and (2) whether the district court erred in its application of the law. State by Cooper v. French, 460 N.W.2d 2, 4 (Minn. 1990). When the district court grants summary judgment based on the application of a statute to undisputed facts, the result is a legal conclusion, reviewed de novo by the appellate courts. Lefto v. Hoggsbreath Enter. Inc., 581 N.W.2d 855, 856 (Minn. 1998). Further "statutory interpretation is a question of law subject to de novo review." Schonns v. State Farm Mut. Auto. Ins. Co., 621 N.W.2d 743, 745 (Minn. 2001).
Does Minnesota's Good Samaritan law provide immunity from a negligence claim where a layperson attempts to transport an injured person from the scene of an accident to a health-care facility?
Appellant first argues that the district court erred by not directly addressing whether the act of transporting an injured person from the scene of the accident to a hospital falls within the scope of Minnesota's Good Samaritan law.
Courts must first look to the language of the statute to determine its meaning and "ascertain and effectuate the intent of the legislature." Minn. Stat. § 645.16 (2002). If the meaning of a statute is plain and unambiguous on its face, judicial construction is neither necessary nor proper. Occhino v. Grover, 640 N.W.2d 357, 359 (Minn. App. 2001), review denied (Minn. May 28, 2002). But courts are not to give effect to the plain meaning of the statute if it produces absurd results or it is clearly at odds with the policy of the legislation as a whole. Id.
The words and phrases of a statute are to be construed according to the ordinary rules of grammar and according to their most natural and obvious usage, unless such a meaning would subvert the intent of the legislature. Amaral v. Saint Cloud Hosp., 598 N.W.2d 379, 383 (Minn. 1999). Every law shall be construed to give effect to all its provisions. Minn. Stat. § 645.16. Whenever possible, no word or phrase will be deemed superfluous. Amaral, 598 N.W.2d at 384. A statute that has more than one reasonable interpretation is ambiguous, and the ambiguity will be resolved by looking to the intent of the legislature. Occhino, 640 N.W.2d at 360. The canons of construction also demand that substantive policy concerns and legislative intent be examined in order to determine the meaning of a statute. Id.
Minnesota's Good Samaritan law has two main components. The statute imposes a duty to help on anyone present "at the scene of an emergency" who "knows another person is exposed to or has suffered grave physical harm," provided that the person can lend assistance without danger or peril to themselves. Minn. Stat. § 604A.01, subd. 1 (2002). The second component of the statute, in dispute here, provides immunity to any person who:
without compensation or the expectation of compensation, renders emergency care, advice, or assistance at the scene of an emergency or during transit to a location where professional medical care can be rendered, * * * unless the person acts in a willful and wanton or reckless manner in providing the care, advice, or assistance. Minn. Stat. § 604A.01, subd. 2(a) (Emphasis added).
Appellant contends that the Good Samaritan law's "during transit" provision does not apply to the mere act of driving an injured party from the scene of an accident to a hospital. Instead appellant argues tha
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