## Facts

- David Spaulding, then a minor, was injured as a passenger in an automobile collision involving vehicles driven by John Zimmerman and Florian Ledermann (owned by John Ledermann).
- Spaulding’s initial medical evaluations documented serious chest, head, and clavicle injuries, but did not report an aortic aneurysm.
- Defendants’ insurer arranged an independent medical examination that discovered Spaulding had a potentially life-threatening aortic aneurysm that could have been caused by the accident.
- Defendants and their counsel knew of the aneurysm before settlement, while Spaulding, his family, their counsel, and the approving court did not.
- The parties settled Spaulding’s claim for $6,500, and because he was a minor, the district court approved the settlement; releases were executed and the action was dismissed with prejudice.
- About two years later, the aneurysm was discovered in a routine examination; Spaulding underwent surgery and then learned it had been identified before settlement by defendants’ physician.

## Issues

1. Whether a district court may, under Minn. R. Civ. P. 60.02(6), vacate a court-approved minor settlement when a distinct, separate injury was unknown to the minor and court at approval but known to defendants and not disclosed.
2. Whether relief required proof of fraud, bad faith, or a classic mutual mistake regarding the nature and extent of the injuries.
3. Whether equitable considerations (including timing and estoppel arguments) limited the court’s authority to grant Rule 60.02(6) relief.

## Decision

- The Minnesota Supreme Court affirmed the district court’s order vacating the settlement approval.
- The Court held the district court acted within its discretion under Rule 60.02(6) to vacate the approval of a minor’s settlement where a distinct, separate injury was not contemplated at the time of approval.
- The Court upheld vacatur of the releases, the stipulation and order of dismissal with prejudice, and the resulting judgment.

## Legal Principles

- A district court has discretionary authority under Minn. R. Civ. P. 60.02(6) to grant relief from a court-approved settlement on behalf of a minor when the court was unaware at approval of a distinct and separate injury not contemplated in the settlement.
- In this setting, relief need not be conditioned on showing fraud or bad faith, nor on a mutual mistake shared by both sides, when one party knew of the injury and knew the other party and the court lacked that information at settlement approval.
- The court’s supervisory role over minor settlements supports equitable intervention to protect the minor’s interests when later-discovered, separate injuries materially affect the fairness of the approved compromise.
- Estoppel is not established merely because the minor’s earlier submissions addressed other injury risks; failure to identify the undisclosed, separate condition at approval does not bar Rule 60.02(6) relief on these facts.
- Arguments that the settlement was justified by insurance limitations carry no weight where the record does not show those limitations were disclosed to, or considered by, the minor or the approving court.

## Conclusion

The court affirmed reopening a minor’s settled personal-injury case under Rule 60.02(6) because the approving court and minor lacked knowledge of a distinct, potentially fatal injury at the time of approval, while defendants knew of the condition and did not disclose it, making equitable relief appropriate even without formal findings of fraud or mutual mistake.


Spaulding v. Zimmerman, 263 Minn. 346, 116 N.W.2d 704 (Minn. 1962)