Justia Minnesota Supreme Court Opinion Summaries

In 2012, the governing board of Avera Marshall Regional Medical Center notified the hospital’s medical staff that it had approved the repeal of the medical staff bylaws and replaced them with revised bylaws. Avera Marshall’s Medical Staff, Chief of Staff, and Chief of Staff-elect commenced an action seeking a declaration that the Medical Staff had standing to sue Avera Marshall and that the former medical staff bylaws constituted a contract between Avera Marshall and the Medical Staff. The district court granted judgment for Avera Marshall and dismissed the case, concluding that the Medical Staff lacked the capacity to sue under Minnesota law and that the medical staff bylaws did not constitute an enforceable contract between Avera Marshall and the Medical Staff. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Medical Staff has the capacity to sue and be sued under Minnesota law; and (2) the medical staff bylaws constitute an enforceable contract between Avera Marshall and the individual members of the Medical Staff. Remanded. View "Medical Staff of Avera Marshall Reg’l Med. Ctr. v. Avera Marshall" on Justia Law

Minn. Stat. 176.081(1)(a) requires employers and insurers to pay attorney fees calculated by a statutory formula not subject to judicial review. In this case, Respondent injured his back while working for Employer. Employer and its insurer (together, Relators) settled with Respondent. Respondent’s attorney then sought an award of contingent attorney fees in an amount that was calculated by applying the statutory formula in section 176.081 but which disregarded the upper limit set by the formula. Relators objected, arguing that, in the absence of judicial review to ensure a fee award is not excessive, application of the statutory formula violates separation of powers principles. The compensation judge applied the statutory formula and concluded that $13,000 would adequately compensate Respondent’s attorney but refused to consider whether the statutory fee was reasonable. The Workers’ Compensation Court of Appeals affirmed the compensation judge’s fee award. The Supreme Court affirmed, holding (1) the Court will recognize the Legislature’s statutory formula as presumptively reasonable, and, absent exceptional circumstances, further judicial review of an award based on the statutory formula is unnecessary; and (2) Relators failed to present any exceptional circumstances to challenge this presumption. View "David v. Bartel Enters." on Justia Law

LumiData, Inc. is a software company that sells a software program called SOLYS to retail suppliers. Between 2005 and 2008, LumiData did not file Minnesota sales tax returns or pay sales tax on its SOLYS sales. The Commissioner of Revenue assessed sales tax on LumiData’s SOLYS sales for the period at issue, concluding the software sales were subject to sales tax. LumiData appealed the Commissioner’s order to the tax court, arguing that its software sales were nontaxable because modifications it made to its software removed it from the definition of “prewritten computer software” within the meaning of Minn. Stat. 297A.61(17). The tax court upheld the assessment, concluding that SOLYS was taxable, prewritten computer software. The Supreme Court affirmed, holding (1) because LumiData did not separately state its customization charges in its invoices, the tax court correctly concluded that the sales price for SOLYS was taxable as a sale of prewritten computer software; and (2) because the record did not establish that LumiData had reasonable cause to believe that its sales of SOLYS were not taxable, the tax court did not err in upholding the Commissioner’s penalty assessments. View "LumiData, Inc. v. Comm’r of Revenue" on Justia Law

Appellant was stopped by police officers while driving in a 2003 Chevy Tahoe on suspicion that he did not have a valid driver’s license. Appellant was subsequently issued a traffic citation. The officers proceeded to conduct an inventory search of the Tahoe and found 225 grams of methamphetamine. The officers then searched Appellant and found $611 in cash. Appellant was charged with first-degree possession of a controlled substance. The vehicle and cash were seized, and Appellant was served with notice and intent to forfeit the seized property. Appellant filed a civil complaint demanding a judicial determination of forfeiture, arguing that the Fourth Amendment exclusionary rule applies to civil forfeiture actions and that the evidence supporting forfeiture was illegally obtained and must be suppressed. The district court granted summary judgment for the County. The court of appeals affirmed, concluding that the Fourth Amendment exclusionary rule does not apply to civil forfeiture actions. The Supreme Court reversed, holding (1) the exclusionary rule is applicable to civil forfeiture actions brought under Minn. Stat. 609.531-.5319; and (2) Appellant had standing to challenge the forfeiture of the vehicle and cash. Remanded. View "Garcia-Mendoza v. 2003 Chevy Tahoe" on Justia Law

Relator was injured while working for Employer. Relator began receiving workers’ compensation benefits in 2010. In 2012, Relator began receiving a retirement annuity from the Public Employees Retirement Association (PERA). At some point, Relator began receiving federal social security retirement benefits. While Employer was entitled under Minn. Stat. 176.101(4) to offset Relator’s permanent total disability benefits by the amount of her social security retirement benefits, the parties disagreed as to whether Employer was entitled to apply the offset to Relator’s PERA retirement benefits. A compensation judge granted Employer the offset. The Workers’ Compensation Court of Appeals (WCCA) affirmed, concluding that Relator’s PERA retirement annuity was an “old age and survivor insurance benefit.” The Supreme Court reversed, holding that, under the reasoning in Ekdahl v. Independent School District #213, also decided today, section 176.101(4) does not permit permanent total disability benefits to be offset by public employee pension benefits. Remanded. View "Hartwig v. Traverse Care Ctr." on Justia Law

Relator was injured while working for a School District. Relator eventually sought and was awarded permanent total disability (PTD) benefits. Relying on Minn. Stat. 176.101(4) and claiming that the statute authorizes an offset for “any old age and survivor insurance benefits,” the School District sought to offset its PTD benefit payment by the amount of government-service pension benefits Relator was receiving. A compensation judge concluded that the School District was not entitled to the offset. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that government-service pension benefits are included in the phrase “old age and survivor insurance benefits” and therefore can be offset from the School District’s disability-benefit payment. The Supreme Court reversed the WCCA and reinstated the decision of the compensation judge, holding that the phrase “old age and survivor benefits” refers only to federal social security benefits, and therefore, the WCCA erred when it applied section 176.101(4) to Relator’s retirement annuity. View "Ekdahl v. Indep. Sch. Dist. #213" on Justia Law

Employee was injured in a work-related accident. Employee obtained approval for surgery from a union-sponsored benefit plan (the Fund) and proceeded with the surgery at a Hospital. After a hearing, a workers’ compensation judge concluded that the surgery was not reasonable and necessary and ordered Employer to reimburse the Fund for the medical bills but also concluded that Employer could seek reimbursement of the expenses from the medical providers. The Hospital was not given notice of that hearing. Before a second hearing on Employer’s request for reimbursement, the Hospital intervened. The compensation judge ordered the Hospital to reimburse Employer. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that the automatic-reimbursement rule announced in Brooks v. A.M.F., Inc. should be extended to the Hospital because it was not given notice of the first hearing. The Supreme Court reversed after declining to extend its decision in Brooks and require automatic payment of a medical provider’s treatment expenses when an employer fails to give the medical provider notice of its right to intervene in a workers’ compensation proceeding to determine responsibility for those expenses, holding that the Hospital was not entitled to automatic payment of its medical bills for Employee’s treatment. Remanded. View "Gamble v. Twin Cities Concrete Prods." on Justia Law

The Chief Deputy of the Steele County Sheriff’s Office evaluated the performance of Respondent, a sergeant, and gave him a negative review. Respondent appealed the Sheriff’s decision with the Minnesota Department of Administration by submitting a statement explaining why he disagreed with portions of the performance evaluation. The Department summarily dismissed the administrative appeal. The court of appeals reversed and remanded the case for informal resolution or a contested-case proceeding under the Data Practices Act (Act). The Supreme Court affirmed, holding (1) the Department wrongly concluded that Respondent’s appeal categorically fell outside the scope of the Act; (2) there was no support for the Department’s argument that dismissal was proper because the appeal raised new challenges and relied on new evidence; and (3) the Department does not have unqualified and unreviewable authority to dismiss any appeal brought under the Act. View "Schwanke v. Minn. Dep’t of Admin." on Justia Law

In 1984 and 1985, James Stevens injured both shoulders while working for S.T. Services and CNA Insurance Companies (collectively, S.T. Services). In 1994, Stevens and S.T. Services entered into a stipulation for settlement under which the parties agreed that Stevens was permanently totally disabled and would receive ongoing permanent total disability benefits. A compensation judge entered an award on the stipulation, and Stevens received benefits until 2011. Stevens began working as a plumbing specialist in 2008 and disclosed his job to S.T. Stevens but continued to receive workers’ compensation benefits. In 2011, S.T. Services filed a petition with the Workers Compensation Court of Appeals (WCCA) to discontinue paying benefits on the grounds that Stevens was no longer permanently totally disabled. A compensation judge granted S.T. Services’ petition to discontinue, and the WCCA affirmed. The Supreme Court reversed, holding that S.T. Services was not allowed by statute to file a petition to discontinue benefits under the circumstances of this case. View "Stevens v. S.T. Servs." on Justia Law

Employee filed an amended complaint seeking indemnity benefits and medical benefits from compensable injuries to his spine. Employee, however, decided not to pursue his indemnity claims at the compensation hearing. The compensation judge found that Respondent had sustained a Gillette injury to his spine and awarded him medical benefits. Employee subsequently sought reimbursement from Employer for attorney fees under Minn. Stat. 176.081. The compensation judge concluded that Employee was entitled to attorney fees under the statute. Employer appealed, arguing that to be eligible for attorney fees, section 176.081 requires an employee to address all related issues at the same time, and so when Employee pursued only a claim for medical benefits, he forfeited his statutory right to all attorney fees. The Supreme Court affirmed, holding that the compensation judge in this case followed the appropriate legal framework in determining the attorney fee award and did not abuse his discretion in the amount awarded. View "Braatz v. Parsons Elec. Co." on Justia Law