Justia Labor & Employment Law Opinion Summaries

Articles Posted in Minnesota Supreme Court

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The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) affirming a compensation judge's judgment finding that Alapati Noga, a former defensive lineman for the Minnesota Vikings, who now suffers from dementia, was entitled to permanent and total disability benefits, holding that Noga did not satisfy the statute of limitations under Minn. Stat. 176.151. Noga played as a defensive lineman for the Vikings from 1988 until 1992. While playing for the Vikings, Noga experienced head injuries and headaches. In 2015, Noga filed a claim petition for workers' compensation benefits. A compensation judge found that Noga sustained a Gillette injury of "head trauma, brain injury, and/or dementia" that culminated on or about December 1, 1992 and that the injury was a substantial contributing factor to Noga's permanent and total disability.The WCCA vacated certain findings and remanded several issues. On remand, the compensation judge resolved those issues in Noga's favor, determining, among other things, that the statute of limitations was satisfied under Minn. Stat. 176.151 because the Vikings provided Noga with medical care that constituted a "proceeding." The WCCA affirmed. The Supreme Court reversed, holding that the Vikings' provision of care for Noga's head injuries did not constitute a proceeding that prospectively satisfied the statute of limitations. View "Noga v. Minnesota Vikings Football Club" on Justia Law

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The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the judgment of the compensation judge dismissing Petitioner's claim petition seeking workers' compensation benefits for post-traumatic stress disorder (PTSD), which Petitioner claimed resulted from numerous traumatic incidents that he experienced while working, holding that the WCCA erred. At issue on appeal was the correct interpretation of Minn. Stat. 176.011, subs.15(d), which requires an employee seeking workers' compensation benefits where the alleged injury is PTSD arising out of employment to prove that the employee has been diagnosed with PTSD by a licensed psychologist or psychiatrist using the latest version of the Diagnostic and Statistical Manual of Mental Disorders (DSM) in making a diagnosis. The Supreme Court held (1) Minn. Stat. 176.011, subs.15(d) does not require a compensation judge to conduct an independent assessment to verify that the diagnosis of the psychologist or psychiatrist conforms to the PTSD criteria set forth in the DSM before accepting the expert's diagnosis; and (2) the WCCA erred by overriding the compensation judge's choice between two competing medical experts because the expert opinion adopted by the compensation judge had an adequate factual foundation for the diagnosis. View "Smith v. Carver County" on Justia Law

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In this case filed by a bus driver who sought reimbursement for chiropractic services related to her work-related injury the Supreme Court affirmed the decision of the court of appeals to reinstate Plaintiff's arbitration award after the district court vacated the award, holding that a provision in the Minnesota Workers' Compensation Act, Minn. Stat. 176.83, subd. 5(c), did not bar coverage. Plaintiff's employer's workers' compensation carrier agreed to pay workers' compensation benefits to Plaintiff but refused to pay for more than twelve weeks of chiropractic care in accordance with the treatment parameters adopted for purposes of the Act. In accordance with that decision, Plaintiff's first chiropractor stopped treatment after twelve weeks of providing care. Plaintiff then received additional care from a different chiropractor. It was for this care that Plaintiff sought reimbursement from State Farm, her personal automobile no-fault insurer. State Farm denied coverage. An arbitrator ruled in favor of Plaintiff and awarded her the full amount she sought. The district court vacated the arbitrator's award, and the court of appeals reversed. The Supreme Court affirmed, holding that the statutory prohibition on reimbursement in section 176.83, subd. 5(c) is limited to the first provider whose services the workers' compensation payer determined to be excessive. View "Rodriguez v. State Farm Mutual Automobile Insurance Co." on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the decision of an unemployment law judge upholding the determination of the Minnesota Department of Employment and Economic Development that the wages Appellant paid to workers who hold H-2A and J-1 visas are subject to unemployment insurance taxation, holding that the court of appeals did not err in concluding that Appellant owed the taxes. Appellant, a corporation that grows and sells fruits and vegetables, began hiring H-2A and J-1 nonimmigrant visa holders in 2010. In 2016, the Department of Employment and Economic Development determined that Appellant owed $154,726 in unpaid unemployment insurance taxes, mostly on the wages of the H-2A and J-1 visa workers. An unemployment judge upheld the determination, concluding that the visa workers' wages were subject to unemployment insurance taxation under Minnesota law. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant must pay unemployment insurance taxes on these workers' wages. View "Svihel Vegetable Farm, Inc. v. Department of Employment & Economic Development" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming in part and reversing in part the workers' compensation judge's determination that the heirs of relator Richard Island were entitled to interest from Auto-Owners Insurance Group on underpaid disability benefits but that neither penalties nor expenses were warranted, holding that the compensation judge's determinations were supported by substantial evidence. On appeal, the WCCA affirmed the compensation judge's denial of penalties and expenses but reversed the award of interest from the date of each underpayment of disability benefits, concluding that the heirs were not entitled to interest. The Supreme Court disagreed, holding (1) the underpaid benefits must bear interest from the date of each underpayment, and the interest owed under Minn. Stat. 176.221, subd. 7 accrued at the statutory rate in effect at the time the payment was due; and (2) the compensation judge's determinations regarding penalties and expenses were supported by substantial evidence. View "Oseland v. Crow Wing County" on Justia Law

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The Supreme Court reversed the conclusion of the Workers' Compensation Court of Appeals that the medical treatment parameters established under the Workers' Compensation Act do not apply when an employer contests its obligation under the Act to pay for an employee's particular medical treatment. Employee sought workers' compensation benefits for a work injury. Employer paid a lump sum and agreed to pay ongoing medical expenses that were reasonably required to cure and relieve Employee's symptoms. Employer paid for Employee's medical treatment until it determined that Employee's current treatment was no longer reasonable or necessary. Employee then filed a workers' compensation medical request seeking payment to cover the cost of his medications. Employer denied the request. A workers' compensation judge ordered Employer to pay for Employee's medications and treatment, holding that the treatment parameters did not apply to Employee's claim. The Workers' Compensation Court of Appeals affirmed. The Supreme Court reversed, holding (1) the ban on applying the treatment parameters in Minnesota Rule 5221.6020, subpart 2, applies only when an employer denies that it has an obligation under the Act to pay compensation for an alleged workplace injury; and (2) the workers' compensation tribunals erred in concluding that the treatment parameters did not apply to Employee's course of treatment. View "Johnson v. Darchuks Fabrication, Inc." on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment for Respondent on Appellant's complaint alleging that Respondent failed to engage in an interactive process to determine reasonable accommodations for her disability before Respondent ended her employment, holding that genuine factual disputes existed that precluded summary judgment. Appellant brought this action under the Minnesota Human Right Act, Minn. Stat. 363A.01-.44, that included a claim for failure to accommodate her disability. Respondent argued that no interactive process was required under the Act, and regardless, Appellant could not perform the essential functions of her position and continuing her employment posed a serious threat to her health. The Supreme Court reversed the district court's grant of summary judgment for Respondent, holding (1) the Act does not mandate an interactive process; but (2) it was error to grant summary judgment for Respondent because genuine factual disputes existed regarding the essential functions of Appellant's employment and Respondent's defense that there was a "serious threat to the health or safety" of Appellant. View "McBee v. Team Industries, Inc." on Justia Law

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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