Cited by
Opinions in Minnesota that cite Yunker v. Honeywell, Inc., 496 N.W.2d 419.
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Doe A.S., Appellant,
Minn. Ct. App. 2026
See Yunker v. Honeywell, Inc., -24 (Minn. App. 1993), rev. denied (Minn. Apr.
- Jane Doe v. Gavin Patrick Meany, Marie Olseth MD LLC d/b/a West End Consultation Group, ... Minn. Ct. App. 2024
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Jane Doe v. Gavin Patrick Meany, Marie Olseth MD LLC d/b/a West End Consultation Group, ...
Minn. Ct. App. 2024
A negligent-retention claim is based on the premise that employers have a duty “to refrain from retaining employees with known dangerous proclivities.” 2 Yunker v. Honeywell, Inc., (referencing Dean v. St.
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Craig A Reichel, et al., Appellants,
Minn. Ct. App. 2023
v. Magnuson, rev. denied (Minn. July 20, 1995); see also Yunker v. Honeywell , (stating that negligent-supervision claims involve the “ability [of the employer] to control and protect its employees while they are involved in the employer’s business or at the employer’s place of business.”), rev. denied (Minn. Apr.
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Jane Doe, Appellant,
Minn. Ct. App. 2023
See Yunker v. Honeywell, Inc., rev. denied (Minn. Apr.
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Doe 598, Appellant,
Minn. Ct. App. 2023
Yunker v. Honeywell, Inc., rev. denied (Minn. Apr.
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John Doe 121, Appellant,
Minn. Ct. App. 2018
Negligent retention requires that: (1) “the employer becomes aware or should have become aware of problems with an employee that indicated his unfitness;” and (2 ) “the employer fails to take further action such as inve stigating, discharge, or reassi gnment.” Yunker v. Honeywell, Inc., (citation omitted), review denied (Minn. Apr.
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, A17-2080, A17-2081, A18-0015
Minn. Ct. App. 2018
An employer is liable for negligent retention when (1) “during the course of employment, the employer becomes aware or should have become aware of problems with an employee that indicated his unfitness,” (i.e., foreseeability) and (2) “the employer fails 10 to take further action such as investigating, discharge, or reassignment.” (quotation omitted), review denied (Minn. Apr.
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Paul Allen Bray, Appellant,
Minn. Ct. App. 2017
Negligent retention occurs when “during the course of employment, the employer becomes aware or should have become aware of problems with an employee that indicated [the employee’s] unfitness, and the employer fails to take further action such as investigating, discharge, or reassignment.” Yunker v. Honeywell, Inc., review denied (Minn. Apr.
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John Doe 101, et al., Appellants,
Minn. Ct. App. 2017
20, 2002); Yunker v. Honeywell, Inc. , (noting that negligent retention imposes liability for an employee’s intentional tort), review denied (Minn. Apr.
- Jane Doe v. Kmart Corporation Minn. Ct. App. 2017
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Jane Doe v. Kmart Corporation
Minn. Ct. App. 2017
For negligent supervision and retention claims, we note that an employer has a duty to “refrain from retaining employees with known dangerous proclivities.” Yunker v. Honeywell, Inc., -24 (Minn. App. 1993), review denied (Minn. Apr.
- Mark Schaefer v. Cargill Kitchen Solutions, Inc. Minn. Ct. App. 2016
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Mark Schaefer v. Cargill Kitchen Solutions, Inc.
Minn. Ct. App. 2016
Negligence Claims Negligent Retention An employer has the duty “to refrain from retaining employees with known dangerous proclivities.” Yunker v. Honeywell, Inc., review denied (Minn. Apr.
- Richard J. Hartfiel v. Raymond Wilburn Allison, T. J. Potter Trucking, Inc., Westfield Insurance Company, intervenor Minn. Ct. App. 2016
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Richard J. Hartfiel v. Raymond Wilburn Allison, T. J. Potter Trucking, Inc., Westfield Insurance Company, intervenor
Minn. Ct. App. 2016
Negligent retention “The difference between negligent hiring and negligent retention focuses on when the employer was on notice that an employee posed a threat and failed to take steps to insure the safety of third parties.” Yunker v. Honeywell, Inc., review denied (Minn. Apr.
- Johnson v. Peterson 734 N.W.2d 275 Minn. Ct. App. 2007
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Johnson v. Peterson
734 N.W.2d 275
Minn. Ct. App. 2007
Negligent hiring does not *278 rely on the scope of employment, but rather on the “risks created by exposing members of the public to a potentially dangerous individual.” Yunker v. Honeywell, Inc.
- Meinstma v. Loram Maintenance of Way, Inc. 672 N.W.2d 224 Minn. Ct. App. 2003
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Meinstma v. Loram Maintenance of Way, Inc.
672 N.W.2d 224
Minn. Ct. App. 2003
Meinstma argues that the incident was violent, and asserts that a violent act by a co-employee against a specific employee is always motivated by personal reasons, citing Yunker v. Honeywell, Inc.
- Olson v. First Church of Nazarene 661 N.W.2d 254 Minn. Ct. App. 2003
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Olson v. First Church of Nazarene
661 N.W.2d 254
Minn. Ct. App. 2003
b. Negligent retention In Minnesota, generally, an employer has the duty “to refrain from retaining employees with known dangerous proclivities.” Yunker v. Honeywell, Inc., review denied (Minn. Apr.
- J.M. v. Minnesota District Council of the Assemblies of God 658 N.W.2d 589 Minn. Ct. App. 2003
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J.M. v. Minnesota District Council of the Assemblies of God
658 N.W.2d 589
Minn. Ct. App. 2003
Church’s liability for negligent retention Generally, an employer has the duty “to refrain from retaining employees with known dangerous proclivities.” Yunker v. Honeywell, Inc., review denied (Minn. Apr.
- Odenthal v. Minnesota Conference of Seventh-Day Adventists 657 N.W.2d 569 Minn. Ct. App. 2003
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Odenthal v. Minnesota Conference of Seventh-Day Adventists
657 N.W.2d 569
Minn. Ct. App. 2003
Minnesota has long recognized that an employer has the “duty to refrain from retaining employees with known dangerous proclivities.” Yunker v. Honeywell, Inc., (citation omitted), review denied (Minn. Apr.
- L.M. Ex Rel. S. v. Karlson 646 N.W.2d 537 Minn. Ct. App. 2002
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L.M. Ex Rel. S. v. Karlson
646 N.W.2d 537
Minn. Ct. App. 2002
Yunker v. Honeywell, Inc., (quotation omitted), review denied (Minn. April 20, 1993).
- Benson v. Northwest Airlines, Inc. 561 N.W.2d 530 Minn. Ct. App. 1997
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Benson v. Northwest Airlines, Inc.
561 N.W.2d 530
Minn. Ct. App. 1997
Yunker v. Honeywell, Inc., review denied (Minn. April 20, 1993).
- Bruchas v. Preventive Care, Inc. 553 N.W.2d 440 Minn. Ct. App. 1996
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Bruchas v. Preventive Care, Inc.
553 N.W.2d 440
Minn. Ct. App. 1996
Yunker v. Honeywell, Inc., review denied (Minn. Apr.
- Oslin v. State 543 N.W.2d 408 Minn. Ct. App. 1996
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Oslin v. State
543 N.W.2d 408
Minn. Ct. App. 1996
Yunker v. Honeywell, Inc., review denied (Minn. Apr.
- M.L. v. Magnuson 531 N.W.2d 849 Minn. Ct. App. 1995
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M.L. v. Magnuson
531 N.W.2d 849
Minn. Ct. App. 1995
725, 732 (D.Minn.1994); Yunker v. Honeywell, Inc., pet.
- P.L. v. Aubert 527 N.W.2d 142 Minn. Ct. App. 1995
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P.L. v. Aubert
527 N.W.2d 142
Minn. Ct. App. 1995
This theory of recovery imposes liability for an employee's intentional torts when the employer “knew or should have known that the employee was violent or aggressive and might engage in injurious conduct.” Yunker v. Honeywell, Inc., pet.
- Anderson Ex Rel. Anderson v. Shaughnessy 519 N.W.2d 229 Minn. Ct. App. 1994
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Anderson Ex Rel. Anderson v. Shaughnessy
519 N.W.2d 229
Minn. Ct. App. 1994
See Yunker v. Honeywell, Inc., (breach and causation are generally questions for jury), pet.