Justia Labor & Employment Law Opinion Summaries

Kelly Dennis was allegedly injured in the course of his employment with The Salvation Army. Dennis filed a claim for workers’ compensation benefits, but The Salvation Army and its insurer (collectively, Relators) denied liability. The compensation judge awarded Dennis benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed. Within thirty days, Relators filed a petition for a writ of certiorari with the clerk of the appellate courts. Relators, however, failed to serve a cost bond on the WCCA as required by Minn. Stat. 176.471. Relators subsequently served an untimely cost bond on the WCCA. At issue before the Supreme Court was whether timely service of the cost bond was mandatory to have the WCCA order reviewed by the Supreme Court on certiorari. The Supreme Court discharged the writ of certiorari and dismissed the appeal, holding that Relators’ failure to file the cost bond within the thirty-day period to appeal was fatal to their appeal. View "Dennis v. Salvation Army" on Justia Law

Employee was injured while participating in an annual employee-recognition event sponsored by Employer. Employee petitioned for workers’ compensation benefits, but Employer denied liability, arguing that Employee’s injury was excluded from coverage under Minn. Stat. 176.021(9), which exempts from workers’ compensation coverage injuries incurred during “voluntary recreational programs.” A compensation judge concluded that the employee-recognition event was not a “voluntary” program because it occurred during Employee’s shift, and he was required to attend in order to obtain his wage without sacrificing his vacation time. The Workers’ Compensation Court affirmed. The Supreme Court affirmed, holding (1) an employer-sponsored recreational program is not “voluntary” when it takes place during work hours and employees must either attend the event or risk forfeiting pay or benefits; and (2) the relevant inquiry when applying section 176.021(9) is whether the program is voluntary, not whether individual recreational activities within the program are voluntary. View "Shire v. Rosemount, Inc." on Justia Law

Respondent fell and was injured during the course of his employment with The Salvation Army. A workers compensation judge awarded Defendant benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed the findings and order of the compensation judge. Relators subsequently filed a timely petition for a writ of certiorari with the clerk of the appellate courts. Relators’ filing, however, did not include a cost bond. The clerk provided Relators with a conformed writ, which Relators served on Respondent and the WCCA. The WCCA notified the clerk of court that Relators had not served a cost bond on the WCCA as required by Minn. Stat. 176.471(3). Relators then served a cost bond on the WCCA. Respondent argued that the plain and unambiguous language of section 176.471 required timely service of a cost bond to effect the Supreme Court’s review. The Supreme Court held that because Relators did not timely serve a cost bond upon the WCCA as required by section 176.471(3) the writ of certiorari must be discharged and the appeal dismissed. View "Dennis v. The Salvation Army" on Justia Law

Terry Boyd filed this lawsuit against BNSF Railway Company, his former employer, under the Federal Employers’ Liability Act (FELA) after being injured in the course of his employment. Boyd later made a settlement offer, which BNSF rejected. The jury returned a verdict and award against BNSF. The district court ordered BNSF to pay double costs to Boyd pursuant to Minn. R. Civ. P. 68.03(b)(2), which provides for additional costs and disbursement incurred after an offer is rejected by a defendant and the relief awarded is less favorable to the defendant than the rejected offer. BNSF sought review, arguing that an award of double costs under Rule 68.03(b)(2) is preempted by FELA. The court of appeals affirmed. The Supreme Court reversed, holding that because double costs are substantive, rather than procedural, and are not authorized by federal law, FELA preempts the application of Rule 68.03(b)(2) in a state court FELA action. View "Boyd v. BNSF Railway Co." on Justia Law

Plaintiff, a former employee of the Minneapolis Public Schools (MPS), was notified on April 22, 2008 that her position would be eliminated. Plaintiff’s last day of work was June 30, 2008. Plaintiff commenced this lawsuit against MPS on June 29, 2010, asserting retaliation in violation of the Minnesota Whistleblower Act (MWA). The district court dismissed Plaintiff’s MWA claim on statute of limitations grounds. The court of appeals reversed, concluding that Plaintiff’s claim was subject to a six-year limitations period, as provided by Minn. Stat. 541.05(1)(2). On appeal, MPS argued that Plaintiff’s claim was subject to the two-year limitations period found in Minn. Stat. 541.07(1). The Supreme Court affirmed, holding that Plaintiff’s cause of action was governed by the six-year statute of limitations found in section 541.05(1)(2). View "Ford v. Minneapolis Public Schools" on Justia Law

The Minnesota Laborers Health and Welfare Fund (“the Funds”) filed a declaratory judgment action against Granite Re, Inc. seeking clarification of their right to payment on a surety bond. The district court granted summary judgment to Granite Re, concluding, among other things, that the Funds’ lawsuit was time-barred because the Funds failed to commence litigation within the one-year contractual limitations period set out in the bond. The court of appeals reversed and remanded, concluding that fraudulent concealment by the bond principal tolled the limitations period set out in the bond. The Supreme Court affirmed, holding (1) fraudulent concealment can be applied to a surety that was not involved in the fraudulent concealment by the principal; and (2) therefore, the one-year contractual limitations period set out in the bond may be tolled against Granite Re. View "Minn. Laborers Health & Welfare Fund v. Granite Re, Inc." on Justia Law

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law

Appellant applied for unemployment benefits after she learned her temporary daytime position would be unavailable after the holiday season. Employer subsequently terminated Appellant from her position. Appellant filed an action against Employer for wrongful discharge, alleging that Employer violated public policy but terminating her employment in retaliation for her application for unemployment benefits. The district court granted summary judgment for Employer and awarded Employer costs and disbursements. The court of appeals affirmed, concluding that although “an employer may be liable for wrongful discharge if it terminates an employment relationship because of the employee’s refusal to violate the law,” Appellant’s claim did not come within the exception to the employment-at-will rule. The Supreme Court affirmed, holding (1) the public policy exception to the employment-at-will rule does not apply to a termination resulting from an employee’s application for unemployment benefits; and (2) the district court does not have discretion to consider a non-prevailing party’s status as an indigent litigant when it awards costs and disbursements to a prevailing party in a civil action. View "Dukowitz v. Hannon Sec. Servs." on Justia Law

Relator was injured while attending a required training session at the general office of her employer. A workers’ compensation judge denied Relator’s claim for benefits, finding that Relator’s injury did not arise out of and in the course of her employment. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that Relator’s injury arose out of the course of her employment, and therefore, her injury was compensable. The Supreme Court reversed and reinstated the decision of the compensation judge, holding that Relator did not meet her burden to prove her injury arose out of her employment, as required by statute. View "Dykhoff v. Xcel Energy" on Justia Law

Appellants, approximately 750 employees, brought a class action against their employers (Employers), alleging five causes of action, including unlawful deductions made in violation of Minn. Stat. 181.79. The jury found Employers did not violate section 181.79. After the verdict, Appellants unsuccessfully requested judgment as a matter of law (JMOL) on their section 181.79 claim. The Supreme Court reversed, holding that Appellants were entitled to JMOL on their claim under section 181.79, as there was no legally sufficient basis for a reasonable jury to find that Employers did not make unlawful deductions from Appellants' wages in violation of section 181.79. Remanded with instructions to enter JMOL in favor of Appellants on liability for their section 181.79 claim. View "Karl v. Uptown Drink, LLC" on Justia Law