MN No-Fault Includes Household Services, Even if Not Replaced

Minnesota case law summary by Attorney Richard Clem: No-Fault.

Carmen Schroeder v. Western National Mutual Insurance Company. MN no-fault

Under the Minnesota No-Fault Act, Minn. Stat. 65B.41-.71, an injured insured who has primary responsibility for the management of a household is entitled to the reasonable value of the insured’s household care and maintenance services, regardless of whether the services were replaced when the insured could not perform them.

No. A13-2289 (Minn. Ct. App. July 7, 2014).

Please see the original opinion for the court's exact language.


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Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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