M.H. and J.L.H. v. Caritas Family Services

M.H. and J.L.H. (plaintiffs) adopted an infant, C.H., through Caritas Family Services (defendant), a Catholic adoption agency, which disclosed some history of incest in C.H.'s background. As C.H. grew older and developed serious behavioral and emotional problems, the plaintiffs sought more information about his genetic background for his ongoing treatment. Caritas then revealed that C.H.'s biological parents were siblings and that his father was hyperactive with low intelligence and mental-health issues, though it described the father as otherwise in good health. The plaintiffs sued for intentional and negligent misrepresentation, later adding claims for emotional distress and punitive damages, alleging Caritas had known but failed to disclose the full genetic and medical picture earlier. The trial court granted summary judgment to Caritas on the intentional-misrepresentation and emotional-distress claims but let the negligent-misrepresentation claim proceed; the appellate court reversed, and the Minnesota Supreme Court took the case.