Articles Posted in Minnesota Supreme Court

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The Supreme Court affirmed the decision of the workers’ compensation court of appeals (WCCA) reversing the workers’ compensation judge’s dismissal of Respondent’s petition for temporary total disability (TTD) benefits under the Minnesota Workers’ Compensation Act, holding that there is no statutory authority for an offset of workers’ compensation benefits by the amount of benefits paid under an employer’s self-funded, self-administered short-term disability (STD) plan. After awarded TTD benefits to Respondent, the compensation judge determined that Respondent’s employer (Employer) was entitled to offset those benefits by the amount of STD benefits already paid. Because Employer had already paid STD benefits in essentially the same amount that would be owed as TTD benefits, the compensation judge then dismissed Respondent’s petition. The WCCA reversed. The Supreme Court affirmed, holding that the WCCA did not err in determining the Employer was not entitled to offset its workers’ compensation liability to Respondent by the amount of STD benefits it paid to Respondent. View "Bruton v. Smithfield Foods, Inc." on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying the motion for summary judgment filed by the City of Minneapolis as to Plaintiff’s claims under the Human Rights Act that the City discriminated against him by failing to accommodate his disability and retaliated against him for seeking an accommodation, holding that Plaintiff’s claims under the Human Rights Act were not barred by the exclusive-remedy provision of the Minnesota Workers’ Compensation Act. In moving for summary judgment, the City argued that Plaintiff’s claims were barred by the exclusivity provision in the Workers’ Compensation Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court overruled its decision in Karst v. F.C. Hayer Co., 447 N.W.2d 180 (Minn. 1989) and reversed, holding that an employee can pursue claims under both the Workers’ Compensation Act and the Human Rights Act because each act provides a distinct cause of action that redresses a discrete type of injury to an employee. View "Daniel v. City of Minneapolis" on Justia Law

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The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that Plaintiff’s injury “arose out of” her employment under the “increased-risk” test the Court applied in Dykhoff v. Xcel Energy, 840 N.W.2d 821 (Minn. 2013). Plaintiff, an employee of Relator, fell down a set of stairs as she was leaving work. The workers’ compensation judge held that the injury did not arise out of employment. The WCCA reversed, determining that the compensation judge applied the incorrect test to determine whether the stairs were hazardous and that the correct test was whether the stairs posed an “increased risk” as opposed to a “neutral risk.” Because the stairs alone increased Plaintiff’s risk of injury, the WCCA concluded that her injury arose out of her employment. The Supreme Court affirmed, holding (1) an injury arises out of employment when there is a causal connection between the injury and the employment; and (2) applying that rule, there was a causal connection between Plaintiff’s injury on the stairway and her employment. View "Roller-Dick v. CentraCare Health System" on Justia Law

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The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that the compensation judge failed fully to consider the extent to which each of Respondent’s employers sought to shift liability to the other employer and that it was error to deny Respondent’s motion for fees under Minn. Stat. 176.191(1). In 2015, Respondent filed a workers’ compensation claim for work-related aggravations to a low-back condition resulting from a work-related injury in 2009. Between the 2009 injury and later aggravations sustained in 2014 and 2015, Respondent’s employer and its insurer changed. When Respondent sought benefits for later aggravations sustained in 2014 and 2015, her 2009-employer and her new employer disputed whether the aggravations were a continuation of the 2009 injury or subsequent injuries for which the new employer and its insurer were liable. The compensation judge held the new employer liable for reasonable benefits for the later injuries but denied Respondent’s claim for fees under section 176.191(1). The WCCA reversed the denial of the motion for fees. The Supreme Court affirmed, holding that the efforts by each employer to shift responsibility to the other employer greatly increased the burden on Respondent’s counsel to provide effective representation, and therefore, Respondent was entitled to receive reasonable attorney fees under the statute. View "Hufnagel v. Deer River Health Care Center" on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers’ Compensation Court of Appeals (WCCA) upholding the decision of the compensation judge ordering that Atlas Staffing, Inc. and its insurer, Meadowbrook Claims Services, pay workers’ compensation benefits to Anthony Gist. The compensation judge found that Gist’s exposure to silica, a known cause of end stage renal disease (ESRD), during his employment with Atlas was a substantial contributing factor to his kidney disease. In the consolidated appeals brought by Appellants and Fresenius Medical Care, which treated Gist after Appellants denied coverage and accepted payments from Medicaid and Medicare for the costs of that treatment, the Supreme Court held (1) the compensation judge did not abuse her discretion by relying on a certain medical report to find that work-related silica exposure was a substantial contributing factor to Gist’s kidney failure; (2) under 42 C.F.R. 447.15, a provider cannot recover payment from third parties for any services billed to Medicaid after the provider has accepted payment from Medicaid for those services; and (3) the WCCA erred when it dismissed Fresenius’s cross-appeal as untimely. View "Gist v. Atlas Staffing, Inc." on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers’ Compensation Court of Appeals (WCCA) upholding the decision of the compensation judge ordering that Atlas Staffing, Inc. and its insurer, Meadowbrook Claims Services, pay workers’ compensation benefits to Anthony Gist. The compensation judge found that Gist’s exposure to silica, a known cause of end stage renal disease (ESRD), during his employment with Atlas was a substantial contributing factor to his kidney disease. In the consolidated appeals brought by Appellants and Fresenius Medical Care, which treated Gist after Appellants denied coverage and accepted payments from Medicaid and Medicare for the costs of that treatment, the Supreme Court held (1) the compensation judge did not abuse her discretion by relying on a certain medical report to find that work-related silica exposure was a substantial contributing factor to Gist’s kidney failure; (2) under 42 C.F.R. 447.15, a provider cannot recover payment from third parties for any services billed to Medicaid after the provider has accepted payment from Medicaid for those services; and (3) the WCCA erred when it dismissed Fresenius’s cross-appeal as untimely. View "Gist v. Atlas Staffing, Inc." on Justia Law

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The Minnesota Fair Labor Standards Act (MFLSA), Minn. Stat. 177.21-.35, provides a private cause of action for an employee who is discharged for refusing to share gratuities. The Supreme Court affirmed the judgment of the court of appeals reversing the dismissal of Employee’s complaint alleging a violation of the MFLSA for Employer’s decision to terminate him for not “properly sharing his tips.” In dismissing the complaint, the district court concluded that the MFLSA does not recognize a wrongful-discharge cause of action. The court of appeals reversed. The Supreme Court affirmed, holding that the MFLSA, by express wording, provides a cause of action for an employee who is terminated for refusing to share tips. View "Burt v. Rackner, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the Workers’ Compensation Court of Appeals (WCCA) in this workers’ compensation case, holding that the compensation judge applied the wrong legal standard in granting Employer’s petition to discontinue Employee’s rehabilitation services. Relying on the definition of “qualified employee” in an administrative rule, the compensation judge concluded that because Employee had obtained “suitable gainful employment” she was no longer eligible for rehabilitation benefits. The WCCA reversed, ruling that an employer must show “good cause” before terminating rehabilitation benefits. The Supreme Court agreed, holding that when an individual receiving rehabilitation benefits no longer meets the definition of a “qualified employee,” a compensation judge may not terminate benefits without first applying the good-cause standard. View "Halvorson v. B&F Fastener Supply" on Justia Law

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The 2013 amendment to the Minnesota Whistleblower Act defining the term “good faith” eliminated the judicially created requirement that the putative whistleblower act with the purpose of “exposing an illegality.” Appellant filed a complaint in the United States District Court for the District of Minnesota alleging that Employer wrongfully terminated his employment in violation of the Minnesota Whistleblower Act. Employer argued in response that Defendant’s conduct was not protected under the Act. Employer based this argument on the Supreme Court’s interpretation of the Act in Obst v. Microtron, Inc., 614 N.W.2d 196, 202 (Minn. 2000), in which the court held that “good faith” requires a putative whistleblower to act with the purpose of “exposing an illegality.” Appellant argued in response that Obst is no longer good law following a 2013 amendment to the Act that defines “good faith” to mean “conduct that does not violate section 181.932, subdivision 3.” The district court certified the question to the Supreme Court as to whether the 2013 amendment abrogated the Supreme Court’s prior interpretation of “good faith.” The Supreme Court answered the certified question in the affirmative. View "United States District Court, District of Minnesota v. Edwards Lifesciences, LLC" on Justia Law

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The Supreme Court affirmed the Workers’ Compensation Court of Appeals’ (WCCA) reversal of the compensation judge’s dismissal of Respondent’s request for benefits under the Minnesota Workers’ Compensation Act (Minnesota Act). At the time of his injury, Respondent was performing longshoreman work. The compensation judge concluded that the Longshore and Harbor Workers’ Compensation Act provided Respondent’s exclusive remedy and that the case should be dismissed under the doctrine of forum non conveniens. The WCCA reversed, determining that the compensation judge’s dismissal for lack of jurisdiction was contrary to law and that the compensation judge lacked authority to dismiss Plaintiff’s claims under the doctrine of forum non conveniens. The Supreme Court affirmed, holding that the compensation judge had jurisdiction to hear Respondent’s claims brought under the Minnesota Act and that the judge abused his discretion by dismissing Respondent’s claims under the doctrine of forum non conveniens. View "Ansello v. Wisconsin Central, Ltd." on Justia Law