Justia Minnesota Supreme Court Opinion Summaries

In September 2015, Bobby Lykins suffered severe physical and cognitive injuries from a work-related explosion. In 2017, Lykins, his employer Anderson Contracting, Inc., and its insurer SFM Mutual Insurance Co. agreed to a workers’ compensation settlement. An addendum to the settlement was agreed upon in 2018. Both agreements were approved by a compensation judge. In 2022, a conservator was appointed for Lykins, who then petitioned the Workers’ Compensation Court of Appeals (WCCA) to set aside the settlements, alleging they were invalid due to Lykins’ incapacity at the time of signing and fraud by omission.The WCCA found that the evidence raised significant questions about Lykins’ capacity when he signed the settlements and referred the matter to a compensation judge for further fact-finding. The WCCA instructed that if the compensation judge found Lykins appeared to be incapacitated at the time of the settlements, the matter should be referred to district court for a determination of incapacity.The Minnesota Supreme Court reviewed the case and clarified that the WCCA has the authority under Minnesota Statutes section 176.521, subdivision 3, to set aside an award if the settlement is invalid under section 176.521, subdivision 1(a). The Court affirmed the WCCA’s decision to refer the matter for fact-finding but vacated the part of the WCCA’s decision that required referral to district court. The Supreme Court held that the workers’ compensation courts have the authority to determine whether Lykins was incapacitated when he signed the settlements. The case was affirmed in part and vacated in part. View "Lykins vs. Anderson Contracting, Inc." on Justia Law

Rodney Dean Bjornson, the relator, suffered two injuries while employed by McNeilus Companies, Inc. He received treatment at Mayo Clinic, with expenses paid by United Healthcare Services. Bjornson's attorney, David C. Wulff, sought Roraff fees for recovering medical benefits. The compensation judge awarded Wulff $49,000 in Roraff fees, finding that United paid $327,257.37 in medical benefits based on itemized medical bills from Mayo Clinic attached to Bjornson's Employee’s Claim Petition.The Workers’ Compensation Court of Appeals (WCCA) reviewed the case and concluded that the itemized bills from Mayo Clinic were not in the appellate record. The WCCA reversed the compensation judge’s award of Roraff fees due to insufficient evidence regarding the bills and modified the Roraff fees to $500, as per the statutory formula for unascertainable benefits amounts.The Minnesota Supreme Court reviewed the case to determine if Wulff presented sufficient evidence of the ascertainable dollar value of medical benefits. The court found that the WCCA did not assess whether the remaining evidence, including Wulff’s testimony and exhibits, was adequate to support the compensation judge’s conclusion. The Supreme Court reversed the WCCA's decision and remanded the case for further proceedings. The WCCA was directed to clarify whether the itemized medical bills were actual bills or a summary document and to determine if the evidence in the record was adequate to support the compensation judge’s conclusion. View "Bjornson v. McNeilus Companies, Inc." on Justia Law

Dawn Simonson was employed by Douglas County as a histologist and suffered a lower back injury in 1996 while performing her job duties. The injury left her permanently and totally disabled, and she received workers' compensation benefits. When Simonson turned 67 in 2023, her employer stopped paying her permanent total disability (PTD) benefits based on a statutory retirement presumption. Simonson claimed she would have worked past age 67 and sought to rebut the presumption.A compensation judge initially found that Simonson had not rebutted the retirement presumption, applying factors from a previous case, Davidson v. Thermo King. The judge concluded that Simonson's intent to retire weighed in favor of the employer, while her financial need weighed in her favor, and other factors were neutral or irrelevant. The Workers’ Compensation Court of Appeals (WCCA) reversed this decision, concluding that the proper standard of proof to rebut the presumption was a preponderance of the evidence and that Simonson had met this burden based on her financial need.The Minnesota Supreme Court reviewed the case and affirmed the WCCA's determination that the preponderance-of-the-evidence standard applies when an employee seeks to rebut the retirement presumption. However, the Supreme Court found that the WCCA erred in emphasizing financial need as the primary factor. Instead, the court held that the relevant question is whether the employee would have retired anyway, even if not disabled, considering various factors such as the availability of work, retirement arrangements, age, work history, and willingness to forgo social security benefits. The case was remanded to the compensation judge for further findings consistent with this opinion. View "Simonson v. Douglas County" on Justia Law

A minor, through his mother, filed a lawsuit against Best Academy after his teacher, Aaron Hjermstad, sexually assaulted him. Hjermstad had a history of sexual abuse allegations from his previous employment, which Best Academy did not uncover during their hiring process. The school did not obtain reference letters or contact references, which were part of their hiring protocol.The district court granted summary judgment in favor of Best Academy, reasoning that hiring decisions are always protected by the discretionary-function exception to municipal tort liability under Minnesota Statutes section 466.03, subdivision 6. The court of appeals affirmed this decision, applying the same reasoning.The Minnesota Supreme Court reviewed the case and concluded that a municipality’s hiring decision is not categorically a policy-level decision involving weighing competing economic, social, political, and financial considerations. The court emphasized that the discretionary-function exception should be interpreted narrowly and that municipalities bear the burden of proving that their conduct involved such considerations. The court found that Best Academy did not provide evidence that its decision not to investigate Hjermstad’s background was based on balancing policy considerations. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "Minor Doe 601 v. Best Academy" on Justia Law

The case revolves around a social worker, Janine Tea, who claimed to have developed post-traumatic stress disorder (PTSD) due to her exposure to the details of a murder committed by one of her clients. The county initially provided workers’ compensation benefits to Tea but discontinued those benefits after a licensed psychiatrist concluded she did not have PTSD. Tea objected to the discontinuance of her benefits and underwent an independent psychological evaluation in which she was diagnosed with PTSD. The compensation judge determined that Tea has compensable PTSD.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge's decision. The county appealed, arguing that Tea did not meet the diagnostic criteria for PTSD listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM).The Supreme Court of Minnesota affirmed the WCCA's decision. The court held that the WCCA’s affirmance of the compensation judge’s finding that Tea has compensable PTSD is not manifestly contrary to the evidence. The court also held that the WCCA did not err in refusing to use the DSM to re-evaluate the compensation judge’s factual finding that Tea has PTSD. The court clarified that compensation judges may review the DSM criteria when considering the persuasiveness of expert reports, but judges may not use those criteria to make their own diagnosis of a claimant’s condition. View "Tea vs. Ramsey County" on Justia Law

In the case before the Supreme Court of Minnesota, clerical and technical employees of the Anoka County Sheriff's Office, represented by the Law Enforcement Labor Services, Inc. (the Union), submitted a petition to the Bureau of Mediation Services (the Bureau) to determine an appropriate collective bargaining unit. The County opposed the unit, proposing a broader, county-wide unit. The Bureau found the County's unit to be the more appropriate choice. The Union appealed this decision, arguing that the Bureau had made numerous errors of law.The Supreme Court held that the Bureau did not improperly compare the Union's proposed unit to that of the County's. The Court determined that under the Public Employment Labor Relations Act (PELRA), overfragmentation is one of the "other relevant factors" that the Bureau is allowed to consider when analyzing statutory factors for a unit determination. However, the Court found that the Bureau gave priority and effectively controlling weight to its four-unit preference and the related overfragmentation concerns over the specific factors listed in PELRA. This was deemed to be an error of law.Consequently, the Court reversed the decision of the Bureau and remanded for further proceedings, instructing that a bargaining unit determination must now be made by the Bureau giving appropriate weight and consideration to the statutory factors in PELRA. View "Anoka County, Minnesota vs. Law Enforcement Labor Services, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the underlying First Amendment retaliation claim brought under 42 U.S.C. 1983 was time-barred, holding that the continuing violation doctrine did not apply to toll the statute of limitations.Plaintiff brought this action alleging that Defendant, the City of Duluth, retaliated against him in violation of his rights under the First Amendment by making false statements and engaging in other negative conduct toward him. In dismissing the claim, the trial court rejected Plaintiff's reliance on the continuing violation doctrine. The court of appeals reversed and reinstated Plaintiff's section 1983 retaliation claim against the City, concluding that the continuing violation doctrine did not apply because the acts Plaintiff alleged as retaliation were discrete acts that were actionable when committed and therefore did not constitute a continuing violation that tolled the statute of limitations. The Supreme Court affirmed, holding that the continuing violation doctrine did not apply in this case. View "Ringsred v. City of Duluth" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversed the judgment of the district court denying Hennepin Healthcare System, Inc.'s motion to vacate an arbitration award in favor of AFSCME Minnesota Council 5, holding that the court of appeals erroneously substituted its own judgment for that of the arbitrator.Hennepin Healthcare and AFSCME, which represented two bargaining units of Hennepin Healthcare employees, arbitrated a dispute regarding Hennepin Healthcare's use of temporary staffing agency workers. The arbitrator issued an award in favor of AFSCME. The district court confirmed the award. The court of appeals reversed, concluding that because the arbitration award did not draw its essence from the collective bargaining agreement it must be vacated. The Supreme Court reversed, holding that Hennepin Healthcare failed to meet its burden to demonstrate that the arbitrator clearly exceeded the powers granted to him in the CBA because the award failed the essence test. View "Hennepin Healthcare System, Inc. v. AFSCME Minnesota Council 5, Union" on Justia Law

The Supreme Court affirmed the judgment of the workers' compensation court of appeals (WCCA) affirming the findings and conclusions of the compensation judge determining that Employee was entitled to workers' compensation benefits because of her Gillette injury, holding that the WCCA's affirmance of the compensation judge's findings was not manifestly contrary to the evidence.Employee filed a claim petition alleging that she sustained a Gillette injury and sought workers' compensation benefits. The compensation judge ordered Employer to pay Employee benefits. The WCCA affirmed. The Supreme Court affirmed, holding that the WCCA's findings, including the date Employee's injury occurred, when Employee was required to notify Employer of her injury, and the calculation of Employe's post-injury earning capacity, were not manifestly contrary to the evidence. View "Schmidt v. Wal-Mart Stores, Inc." on Justia Law

In this appeal arising out of the application of a provision of the Minnesota Workers' Compensation Act known as the "assault exception" the Supreme Court held that the assault exception applied and that Relator Deangelo Profit was not entitled to recover workers' compensation benefits under the circumstances of this case.Profit suffered serious injuries when he was attacked at his job site by a mentally ill acquaintance while he was performing his work injuries. Profit sought workers' compensation benefits under Minn. Stat. 176.021, subd. 1, which are to awarded in cases "of personal injury or death of an employee arising out of and in the course of employment." The Workers' Compensation Court of Appeals concluded that Profit was not entitled to recover benefits under the assault exception. The Supreme Court affirmed, holding that the assault exception did not apply where the assailant "intended to injure [Profit] because of personal reasons" and his acts were "not directed against the employee as an employee, or because of the employment." View "Profit v. HRT Holdings" on Justia Law