Justia Labor & Employment Law Opinion Summaries

The Workers’ Compensation Court of Appeals (WCCA) clearly and manifestly erred by rejecting the findings of the compensation judge and overturning the determination that Respondent failed to establish her claim for benefits by a preponderance of the evidence. Respondent filed a claim for workers’ compensation benefits after falling and injuring her shoulder while rushing up a staircase at the workplace of her employer. The compensation judge denied the claim. The WCCA reversed the compensation judge’s decision. The Supreme Court reversed the WCCA’s decision and reinstated the compensation judge’s decision, holding (1) the WCCA impermissibly substituted its own view of the evidence for that of the compensation judge; and (2) the findings of the compensation judge were supported by substantial evidence that a reasonable mind would accept as adequate. View "Kubis v. Community Memorial Hospital Ass’n" on Justia Law

Anibal Sanchez, an undocumented worker, brought suit against Dahlke Trailer Sales, Inc. under the workers’ compensation antiretaliation statute, alleging that Dahlke discharged him because he sought workers’ compensation benefits. The district court granted summary judgment to Dahlke, finding as a matter of law that Sanchez’s unpaid leave was a result of his immigration status and not his workers’ compensation claim. The court of appeals reversed. The Supreme Court affirmed and remanded the case for further proceedings, holding (1) Sanchez raised a genuine issue of material fact as to whether Dahlke discharged him and as to whether the discharge was motivated by Sanchez seeking workers’ compensation benefits; and (2) federal immigration law does not preempt an undocumented worker’s claim that his employer discharged him in retaliation for seeking workers’ compensation benefits. View "Sanchez v. Dahlke Trailer Sales, Inc." on Justia Law

The Workers’ Compensation Court of Appeals (WCCA) was correct in concluding that Respondent’s injury was compensable.Respondent, who was employed by the University of Minnesota, slipped and fell on any icy sidewalk when walking from her workplace to a parking ramp owned and operated by the university. The compensation judge denied Respondent’s claim for workers’ compensation benefits, concluding that Respondent’s injury did not “arise out of” her employment. The WCCA reversed, concluding that Respondent was in the course of her employment when she was injured. The Supreme Court affirmed, holding that Respondent’s injury was compensable because it both arose out of, and was in the course of, her employment. View "Hohlt v. University of Minnesota" on Justia Law

The Workers’ Compensation Court of Appeals (WCCA) abused its discretion when it granted Eddie Hudson’s petition to vacate an award of workers’ compensation benefits. Hudson was injured while working for Trillium Staffing and filed a workers’ compensation claim. The parties eventually settled. About one year later, Hudson filed a petition to vacate the award. The Workers’ Compensation Court of Appeals (WCCA) granted the petition, finding that Hudson’s medical condition had substantially changed in a way that clearly was not, and could not reasonably have been, anticipated at the time of the award. The Supreme Court reversed, holding that the WCCA abused its discretion when it granted Hudson’s petition because the medical opinion underlying the WCCA’s decision lacked foundation and therefore did not establish a substantial change in Hudson’s medical condition. View "Hudson v. Trillium Staffing" on Justia Law

In this negligence lawsuit filed against Kraemer Construction, Inc., the Supreme Court held that Kraemer and Ulland Brothers, Inc. were engaged in a common enterprise as a matter of law when Richard Washburn was killed and that the election of remedies provision required dismissal of the suit.Jessica Kelly, as trustee for the next-of-kin of Washburn, filed this lawsuit against Kraemer for its alleged negligence in causing Washburn’s death by electrocution at a construction site. Kraemer moved for summary judgment, arguing that it was engaged in a common enterprise with Ulland, Washburn’s employer, when Washburn was killed and that the election-of-remedies provision of the Minnesota Workers’ Compensation Act prevented Kelly from bringing a civil action against Kraemer when her children had already recovered workers’ compensation benefits from Ulland. The court of appeals reversed the district court’s denial of summary judgment and remanded for entry of summary judgment in favor of Kraemer. The Supreme Court affirmed, holding that Kraemer and Ulland were engaged in a common enterprise and that the election of remedies provision required dismissal. View "Kelly v. Kraemer Construction, Inc." on Justia Law

Based on the plain language of Minn. Stat. 176.101, subd. 1(i), the Supreme Court held that an offer to return to work with the same employer is not “consistent with” an employee’s rehabilitation plan stating that the employee’s vocational goal is to return to work with a different employer in the same industry. The Court affirmed the decision of the Workers’ Compensation Court of Appeals that reversed the compensation judge’s decision to discontinue temporary total disability (TTD) compensation to the employee at issue in this case, holding that the employer was not entitled to discontinue TTD benefits because its job offer was not consistent with the employee’s plan of rehabilitation. View "Gilbertson v. Williams Dingmann, LLC" on Justia Law

Respondent worked as a police officer for Appellant City of Minneapolis. When the City transferred Respondent from his position with the Violent Offender Task Force to another police unit Respondent was fifty-four years old. In November 2011, Respondent filed a complaint with Appellant’s human resources department, claiming that the transfer was due to age discrimination. More than one year after Peterson filed his complaint, Appellant concluded that the transfer was not because of age discrimination. In March 2014, Respondent commenced this action against Appellant, claiming that the City discriminated against him based on his age in violation of the Minnesota Human Rights Act (MHRA). The district court granted partial summary judgment for the City, concluding that Respondent’s claim was not filed within the relevant one-year limitations period. The court of appeals reversed, concluding that the statute of limitations was suspended during the period of time in which Appellant’s human resources department was investigating Respondent’s claim. The Supreme Court affirmed, holding that Respondent and Appellant were voluntarily engaged in a dispute resolution process involving a claim of unlawful discrimination during Appellant’s investigation of Respondent’s claim, which triggered Minn. Stat. 363A.28(3)(b) and suspended the one-year limitations period. View "Peterson v. City of Minneapolis" on Justia Law

After Nicole LaPoint applied for a job with Family Orthodontics, the company’s owner, Dr. Angela Ross, offered LaPoint a job as an orthodontic assistant. When LaPoint told Dr. Ross that she was pregnant, Family Orthodontics rescinded its job offer. LaPoint sued the company for sex discrimination under the Minnesota Human Rights Act. The district court entered judgment in favor of Family Orthodontics. The court of appeals reversed, ruling, as a matter of law, that Family Orthodontics had discriminated against LaPoint because of her pregnancy. The Supreme Court reversed, holding (1) to the extent the court of appeals applied an incorrect legal standard to evaluate LaPoint’s claim, it erred; and (2) the district court’s findings were reasonably supported by the evidence, but it was unclear whether the district court would have made the same findings had it applied the correct law regarding animus. Remanded. View "LaPoint v. Family Orthodontics, P.A." on Justia Law

Respondent received a head injury during the course of her employment. Respondent filed a request with the workers’ compensation division seeking coverage for various treatments she was receiving for her injuries, including treatment for emotional and psychological conditions that allegedly developed from her injury. The compensation judge denied Respondent’s request for coverage of emotional and psychological conditions, finding that Respondent had not suffered a concussion and post-concussive syndrome. The compensation judge relied heavily on the opinion of a certain psychologist. The WCCA reversed and vacated the denial of coverage of the emotional and psychological conditions, concluding that there was not an adequate factual foundation for the psychologist’s opinion. The Supreme Court reversed, holding (1) the WCCA erred when it raised and ruled on the forfeited issue of whether a psychologist was competent to provide an expert opinion; (2) the WCCA erred when it reversed the compensation judge’s decision based primarily on the psychologist’s report; and (3) the WCCA erred when it reversed the compensation judge’s finding that Respondent did not suffer a concussion and post-concussive syndrome. View "Gianotti v. Independent School District 152" on Justia Law

Employee’s employment was terminated after Employer discovered that the representation Employee made in her employment application was not accurate. Employee applied for unemployment benefits with the Department of Employment and Economic Development (DEED). DEED concluded that Employee was eligible to receive unemployment benefits. Employer appealed. An unemployment law judge determined that Employee was ineligible for unemployment benefits because she was discharged for “employment misconduct” under Minn. Stat. 268.095. The court of appeals reversed, concluding that Employee’s conduct did not constitute employment misconduct. The Supreme Court reversed, holding that (1) the court of appeals applied an improper definition of “employment misconduct”; and (2) under the facts and circumstances of this case, Employee was terminated for “employment misconduct” as defined in section 268.095. View "Wilson v. Condon" on Justia Law