Hyatt v. Anoka Police Department

Hyatt v. Anoka Police Department

691 N.W.2d 824 (2005)

Facts:

After sustaining injuries from a police dog during the attempted arrest of her husband, Lena Hyatt filed suit against the Anoka Police Department under Minnesota's dog-bite statute, Minn. Stat. § 347.22. The defendant moved for a summary judgement on the grounds that (1) the dog-bite statute does not apply to police dogs; (2) it has statutory immunity: and (3) the police department is not a legal entity subject to suit. In granting the motion for summary judgement, the Appellate Court found that allowing the dog-biting statute to be applied to police dogs would create "absurd" outcome.

Does the dog bite statute apply to municipal owners of police dogs?

Holding:

In overturning the Appellate Court decision, the Supreme Court found that the police department could be potentially liable under the "plain language" of the dog bite statute.

Reasoning:

In considering the plaintiffs cause of action, the Supreme Court declined to look past the plain meaning of the dog biting statute and consider it's legislative intent. They stressed that courts "could only disregard a statute's plain meaning only in rare cases where the plain meaning utterly confounds a clear legislative purpose." It would therefore be improper to disregard the plain meaning language of Minn. Stat. § 347.22 on the grounds that this plain meaning would create an absurd result. Therefore, while the Appellate Court finding that applying the dog-biting statute to police dogs would lead to absurd outcomes, on the grounds that they are statutory authorized to use reasonable force, the Supreme Court found this reasoning unpersuasive for the following two reasons.