Articles Posted in Labor & Employment 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 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 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

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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 reversed the decision of the Workers' Compensation Court of Appeals (WCCA) to reverse the denial of Respondent's claim for ankle-fusion surgery. Respondent, who was injured during the course of her employment, filed a workers’ compensation claim petition for ankle-fusion surgery. The compensation judge denied Respondent’s claim for the ankle-fusion surgery. The WCCA reversed. Respondent’s employer appealed, arguing that the WCCA exceeded the scope of its review when it reversed the compensation judge’s decision to deny benefits to Respondent. The Supreme Court reversed, holding that the compensation judge’s finding was “supported by evidence that a reasonable mind might accept as adequate,” and therefore, the WCCA clearly and manifestly erred in rejecting this finding. View "Mattick v. Hy-Vee Foods Stores" on Justia Law

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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

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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