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Burck v. Pederson10/11/2005
gislative intent of the statute is to do anything other than what the plain language states, namely, to prohibit evidence of seatbelt use or nonuse in motor-vehicle-accident litigation.
Although it might be argued that the law unfairly prevents a person allegedly injured by a seatbelt from proving the cause of the injury , the result is not absurd if the legislature purposely created the restriction on that proof. It is indisputable that the legislature has the power to create and to limit rights. Limitations can sometimes be criticized as being unfair. The appellants have plausibly shown that the seatbelt gag rule can be unfair when applied in certain circumstances. But they have failed to show that the restriction was not within the purpose of the law.
The conclusion that the legislature intended precisely what the plain language of the statute provides is fortified by the fact that the legislature amended the statute in 1999 to include a products-liability exception but did not in any way alter the prohibition on proof of the use or nonuse of a seatbelt in ordinary motor-vehicle personal-injury litigation. See 1999 Minn. Laws ch. 106, § 1, at 378. The appellants' cited authorities, Lind and Olson, had been decided before the 1999 amendment, and presumably the legislature was aware of the issue regarding the legislative intent of the prohibition when it amended the statute.
In addition to Lind and Olson, Minnesota courts have consistently applied the plain language of the seatbelt gag rule in motor-vehicle personal-injury litigation against both plaintiffs and defendants. See Anker, 541 N.W.2d at 340 (holding that evidence of seatbelt-restraint-system failure is not admissible against vehicle manufacturers); Swelbar v. Lahti, 473 N.W.2d 77, 79 (Minn. App. 1991) (holding that evidence of use of child-restraint system not admissible as defense against wrongful-death claim); and Marsden, 589 N.W.2d at 807 (holding that seatbelt evidence is not admissible in breach-of-contract claim). In Anker and Marsden, we suggested that the application of the plain language of the statute produced a troubling result, but we found no basis for concluding that the result was unintended or was absurd.
DECISION
Because the appellants' evidence of the use of a seatbelt as causing injury falls squarely within the plain meaning of Minn. Stat. § 169.685, subd. 4(a) (2004), the district court did not err in applying the statute so as to preclude the introduction of such evidence at trial. Nor did the court err in treating the evidentiary issue as dispositive and granting summary judgment dismissing the action.
Affirmed.
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