Bjerke v. Johnson

LANSING, Judge

(concurring specially).

On the facts presented in this appeal, Aja Bjerke has established that she had a special relationship with Suzette Johnson when she went to live on Johnson’s farm in 1998 when she was 15 years old. On the basis of that special relationship, together with the facts supporting foreseeability, Bjerke has established a triable issue on whether Johnson had a duty to protect Bjerke from sexual abuse by Johnson’s boyfriend, Kenneth Bohlman, which Bjerke alleges occurred between 1998 and 2001.

Bjerke has also demonstrated that the district court erred by concluding as a matter of law that Bjerke assumed the risk of the injuries she sustained as a result of the sexual abuse. Minnesota’s statutory rape laws are based on the firmly established principle that a child who is under the age of 16 is incapable of consenting to sexual contact with adults. State v. Steinbrink, 297 N.W.2d 291, 293 (Minn.1980). Criminal statutes further establish that children between the ages of 16 and 18 are deemed incapable of consenting to sexual contact with adults if that adult has a significant relationship with or is in a position of authority over the child. Minn. Stat. § 609.344, subd. 1(e)-(f) (2006). The public policy underlying these principles recognizes that children in their mid-teens are susceptible to sexual exploitation because of their inexperience and lack of judgment, which makes them unable to resist external pressures, especially when the pressure is exerted by adults they know and trust, or to whom they are subordinate. See State v. Krotzer, 548 N.W.2d 252, 256 (Minn.1996) (Coyne, J., dissenting) (noting minors’ inability to appreciate potential long-term consequences of sexual conduct), abrogated by State v. Lee, 706 N.W.2d 491 (Minn.2005). Thus a defendant in a civil action should not be permitted to raise assumed risk as a defense against a child under the age of 16, and should only be permitted to raise the defense against a child between the ages of 16 and 18 if the defendant was not in a position of authority over the child and did not have a significant relationship with the child.

The majority attaches significance to the fact that Bjerke was 17 years old at the time of the fourth incident and hinges the availability of the assumed-risk defense on whether Bohlman was in a position of authority at the time. That analysis is incomplete because it does not take into account the facts that establish that Bohl-man had a significant relationship with Bjerke. See Minn.Stat. § 609.341, subd. 15(3) (2006) (stating significant relationship includes adult who resides intermittently or regularly in same dwelling as complainant); State v. Sebasky, 547 N.W.2d 93, 100 (Minn.App.1996) (finding significant relationship when complainants stayed at defendant’s apartment for periods of two to six days), review denied (Minn. June 19, 1996). On these facts, the assumption-of-risk defense is unavailable to Johnson.

For these reasons I would reverse the district court’s summary judgment dismissing Bjerke’s negligence claim. Be*198cause the district court acted within its discretion in bifurcating for trial the claims against Bohlman and Johnson, I would affirm that ruling. I would also affirm the ruling on the punitive-damages motion based on the current record.