Justia Minnesota Supreme Court Opinion Summaries

An applicant for a public sector web developer position was initially offered employment by a state agency, Minnesota IT Services (MNIT), contingent upon a background check. The background investigation revealed the applicant’s 2017 conviction for possession of child pornography. In compliance with the Criminal Offenders Rehabilitation Act (CORA), MNIT determined the conviction directly related to the position and requested evidence of rehabilitation and present fitness from the applicant. The applicant submitted documentation, including an early discharge from probation, evidence of law-abiding behavior since release, a description of the offense’s circumstances, and several reference letters. Despite this, MNIT concluded the conviction disqualified the applicant from employment and imposed a ten-year bar on reapplying.The applicant challenged the disqualification through the Minnesota Administrative Procedure Act. After both parties sought summary disposition, an administrative law judge (ALJ) found the applicant had provided sufficient evidence of rehabilitation and recommended the disqualification be rescinded. The Commissioner of MNIT, however, rejected the ALJ’s legal conclusions and recommendation, and remanded the matter for a contested case hearing. Following a related Minnesota Supreme Court decision clarifying that agencies lacked authority to remand to ALJs under the relevant administrative statute, the ALJ determined he lacked jurisdiction to proceed. The Commissioner then issued a final order affirming the disqualification, allowing the applicant to reapply in 2027. The applicant appealed to the Minnesota Court of Appeals, which reversed the Commissioner’s decision, holding that MNIT lacked discretion to disqualify the applicant after competent evidence of rehabilitation was provided.The Minnesota Supreme Court reviewed the case. It held that the ALJ’s recommendation was not the final decision, as the Commissioner timely rejected it within statutory limits. On the substantive question, the Court found that a public employer retains discretion under CORA to determine whether an applicant has demonstrated sufficient rehabilitation and present fitness after the applicant submits competent evidence. The Court affirmed in part, reversed in part, and remanded for further proceedings. View "McNitt vs. Minnesota IT Services" on Justia Law

A sexual assault counselor employed by a nonprofit mental health organization was asked multiple times by her supervisors to disclose the location and information regarding a minor victim, whom law enforcement and county officials were seeking in connection with a probation violation. The counselor refused to provide this information without the victim’s consent, citing the statutory sexual-assault-counselor privilege. Despite her refusal, and after continued pressure, the counselor was ultimately terminated from her position. She then brought claims against her employer under the Minnesota Whistleblower Act and for common-law wrongful discharge, arguing that disclosing the information would have violated the sexual-assault-counselor privilege.The Washington County District Court granted the employer’s motion to dismiss for failure to state a claim, finding that the facts alleged did not support that the requested disclosure would violate the privilege statute. The Minnesota Court of Appeals affirmed, holding that the sexual-assault-counselor privilege is limited to disclosures made in the context of a court action or proceeding, or before someone authorized to receive evidence, and that the counselor had not alleged such circumstances.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court held that the sexual-assault-counselor privilege in Minnesota Statutes section 595.02, subdivision 1(k), applies only in an “action or proceeding, civil or criminal, in court or before any person who has authority to receive evidence.” Because the counselor did not allege she was ordered to disclose information in such a context, her claims under the Minnesota Whistleblower Act and for common-law wrongful discharge failed as a matter of law. The court declined to extend the privilege or recognize a broader common-law claim, emphasizing that any broader confidentiality protections would need to come from the legislature. View "Wredberg vs. Canvas Health, Inc." on Justia Law

A police officer with 25 years of service sought workers’ compensation benefits after being diagnosed with post-traumatic stress disorder (PTSD). The officer had experienced numerous traumatic events during his career and began psychological treatment in 2021. He was diagnosed with PTSD by a licensed psychologist, who relied on the DSM-5 for the diagnosis. The City, disputing the claim, had its own psychologist conduct an independent psychological evaluation (IPE) using the same DSM edition, who concluded that the officer did not meet the criteria for PTSD but instead had alcohol abuse disorder. Subsequently, the officer’s psychologist conducted a follow-up evaluation using the updated DSM-5-TR, issuing a “lifetime” PTSD diagnosis.A compensation judge found the officer entitled to a statutory presumption that his PTSD was work-related but determined that the City had rebutted this presumption, relying on the City’s expert’s opinion despite it being based on the earlier DSM-5. The judge found the City’s expert more persuasive and denied the officer’s claim for benefits.The Workers’ Compensation Court of Appeals (WCCA) vacated the compensation judge’s order, holding that the City’s expert opinion could not be considered because it was not based on the most recently published DSM edition. The WCCA ruled that only an IPE using the most recent DSM edition could rebut the statutory presumption and made its own finding that the City failed to rebut the presumption.The Minnesota Supreme Court reviewed the case. It held that the most recently published edition of the DSM includes text revisions, but an IPE is not the only way to rebut the statutory presumption. The Court also held that a compensation judge is not barred from considering an IPE based on an outdated DSM edition. The Supreme Court reversed the WCCA’s decision and remanded for consideration of additional arguments not previously addressed. View "Rowe vs. City of Minneapolis" on Justia Law

An employee who had been working remotely due to a pandemic-related order was instructed by her employer to return to the office and begin a new hybrid work schedule. On the day she was to return, she packed her work equipment, which she had been using at home, and attempted to load it into her car earlier than her usual departure time so she could set up her workstation before her normal shift began. During this process, she fell and injured her back. She reported the injury, received medical care, and subsequently sought workers’ compensation benefits for her injury.A workers’ compensation judge initially heard her claim and determined that her injury was not compensable. The judge reasoned that the injury occurred during her commute and did not fall under the special-errand exception, relying on precedent from the Workers’ Compensation Court of Appeals (WCCA) in a prior case. The judge found that transporting the equipment was a routine part of her return-to-work commute and thus not a special errand.The employee appealed to the WCCA, which reversed the compensation judge’s decision. The WCCA found that, unlike the prior case, her employer had implicitly required her to return the work equipment before her shift began, and there was no evidence of backup equipment at the office. This, the WCCA determined, qualified her trip as a special errand.The Supreme Court of Minnesota reviewed the case and affirmed the WCCA’s decision. The court held that the WCCA did not err in making a factual finding that the employer’s directive included an implied request to return equipment before her shift, nor was this finding manifestly contrary to the evidence. The court also held that, as a matter of law, the employee’s injury was compensable under the special-errand exception to the general rule barring compensation for injuries sustained during a commute. View "Ludwig vs. Dakota County, Self-Insured by SFM Risk Solutions" on Justia Law

Employees of a property management company reported to the Minnesota Attorney General that their employer had failed to pay legally required wages and overtime, allegedly using subsidiaries to evade wage laws. Acting on these complaints, the Attorney General issued a civil investigative demand (CID) to the company and its subsidiaries in October 2019, seeking documents relevant to wage practices. The company challenged the CID in court, resulting in over three years of litigation before it ultimately provided the requested documents in July 2022. Following the conclusion of the CID litigation, the Attorney General filed a civil enforcement action in June 2023, alleging violations of the Minnesota Fair Labor Standards Act (MFLSA) related to wage theft.The Ramsey County District Court granted the company’s motion to dismiss the MFLSA claim under Minnesota Rule of Civil Procedure 12.02(e), finding the claim was barred by the two-year statute of limitations set forth in Minn. Stat. § 541.07(5). The court determined the claim accrued by late 2019, when the employees first came forward. The Minnesota Court of Appeals affirmed, rejecting the Attorney General’s argument that litigation over the CID should toll the limitations period, and citing a lack of precedent for such tolling.On review, the Minnesota Supreme Court held that litigation over a civil investigative demand issued under Minn. Stat. § 8.31 tolls the statute of limitations for a subsequent civil enforcement action, provided the CID and the enforcement action concern the same alleged unlawful practice. The Supreme Court reversed the dismissal of the MFLSA claim and remanded the case to the district court for further proceedings, establishing a narrow rule that tolling applies specifically during CID litigation under the Attorney General’s investigative authority. View "State of Minnesota v. Madison Equities, Inc." on Justia Law

An employee began working at a foundry in Minnesota and, after developing back problems, was placed on a lifting restriction by her doctor. She informed her employer of this restriction, but the employer terminated her employment without attempting to provide accommodations. The employee then applied for unemployment benefits, prompting the employer to complete a questionnaire for the Department of Employment and Economic Development (DEED) regarding her termination and disability. In the questionnaire, the employer indicated it had not tried to accommodate her condition.The employee subsequently filed a lawsuit under the Minnesota Human Rights Act, alleging disability discrimination and failure to accommodate. During discovery, the employer sought to exclude the DEED questionnaire from evidence at trial, arguing it was absolutely privileged under Minnesota Statutes section 268.19, subdivision 2(c). The District Court agreed and excluded the document, reasoning that information created solely for unemployment insurance purposes was inadmissible in other civil proceedings. After a bench trial, the District Court ruled in favor of the employer and dismissed the employee’s claims. The Minnesota Court of Appeals affirmed, holding that the questionnaire was absolutely privileged and inadmissible.The Supreme Court of Minnesota reviewed the case to determine whether section 268.19, subdivision 2(c), bars admission of such documents in civil cases. The court held that the phrase “absolutely privileged” in the statute provides immunity from liability for information submitted to DEED, but does not create a general rule of inadmissibility for such evidence in unrelated civil proceedings. Because the employee’s discrimination claim was not based on the content of the DEED questionnaire, its exclusion was erroneous. However, the court found the error was not prejudicial, as the excluded evidence was cumulative of other admitted evidence. The Supreme Court affirmed the decision of the Court of Appeals, but on different grounds. View "McBee vs. Team Industries, Inc." on Justia Law

A middle school math teacher employed by a Minneapolis public school was injured while playing basketball with students during an afterschool practice. The teacher participated in the activity to strengthen relationships with students, which was encouraged by the school’s administration and reflected in the school’s mission and teacher evaluation standards. The injury, a ruptured ACL, occurred approximately 30 minutes after the official end of the teacher’s workday, at the school gym, and required surgery and time off work. The teacher sought workers’ compensation benefits, but the self-insured school district denied liability, arguing the injury did not arise out of or in the course of employment and was excluded under a statutory provision for injuries incurred during voluntary employer-sponsored recreational programs.After an administrative hearing, a workers’ compensation judge found the injury compensable, concluding it arose out of and in the course of employment, and that the statutory exclusion for voluntary recreational programs did not apply because the activity was for the benefit of students, not employees. The school district appealed to the Workers’ Compensation Court of Appeals (WCCA), which affirmed the compensation judge’s decision, agreeing that the exclusion did not bar the claim and that the injury occurred in the course of employment.The Minnesota Supreme Court reviewed the case. It held that the teacher’s injury occurred “in the course of” employment under Minnesota Statutes section 176.021, subdivision 1, because the injury happened at the workplace, within a reasonable time after the workday, and during an employment-related activity. The Court further held that the exclusion in section 176.021, subdivision 9, applies only to voluntary employer-sponsored recreational programs that are for the benefit of employees, not students. The Supreme Court affirmed the WCCA’s decision. View "Lindsay vs. Minneapolis Public School District (SSD1)" on Justia Law

An employee who worked as a packaging operator began experiencing left shoulder pain, which she attributed to her work activities. After seeking medical treatment, including surgery, her employer and its workers’ compensation insurer initially accepted her claim as work-related but later denied it based on an independent medical examination. While the workers’ compensation claim was pending, the employee’s health insurer paid for her medical expenses as required by Minnesota law when compensability is disputed. The employee then filed a workers’ compensation claim seeking a determination that her injury was compensable and that her employer should cover her medical expenses. The health insurer was notified of its right to intervene in the proceedings but did not do so within the statutory deadline.A compensation judge found the employee’s injury was work-related and compensable, but concluded that the employee could not bring a direct claim for medical expenses already paid by her health insurer, reasoning that only medical providers, not insurers, could be the subject of such claims. The judge also ruled that the health insurer’s failure to intervene extinguished its right to reimbursement. The Workers’ Compensation Court of Appeals (WCCA) reversed, holding that the employee could bring a direct claim for the medical expenses paid by the health insurer and that the employer and its insurer must reimburse the health insurer, despite its failure to intervene.The Minnesota Supreme Court reviewed the case. It held that, consistent with its recent decision in Johnson v. Concrete Treatments, Inc., an employee may bring a direct claim under the Workers’ Compensation Act for medical expenses related to a compensable work injury, even if those expenses were paid by a health insurer before compensability was determined. However, the Court also held that the WCCA erred in reviving the health insurer’s independent intervenor interest, which was extinguished by its failure to timely intervene. The Court affirmed in part and reversed in part. View "Brunner vs. Post Consumer Brands" on Justia Law

James Jurgensen sustained a work injury on July 29, 2021, while employed by Dave Perkins Contracting, Inc. He hired attorney Joshua E. Borken, who agreed to a contingent fee of 20% of the first $130,000 of compensation and 20% of any excess amount, subject to approval. Minnesota Statutes § 176.081, subd. 1(a) (2022), caps attorney fees in workers’ compensation cases at $26,000. The parties settled for $150,000, and Borken sought $30,000 in fees, including $4,000 in excess fees. The compensation judge approved $26,000 but denied the excess fees after applying the Irwin factors.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge’s decision, finding no abuse of discretion in denying the excess fees. The WCCA also concluded that automatic approval of unobjected-to excess fees is inconsistent with section 176.081, which provides a presumptive cap on attorney fees. The WCCA did not address the constitutional issue due to a lack of jurisdiction.The Minnesota Supreme Court reviewed the case. The court held that the 2024 amendment to Minn. Stat. § 176.081, which increases the cap on attorney fees, does not apply retroactively. The court also held that the WCCA did not err by declining to automatically approve the requested excess fee. Additionally, the court found that Minn. Stat. § 176.081, subd. 1(a) (2022), does not violate the Contracts Clause of the Minnesota Constitution. Finally, the court concluded that the WCCA did not err by affirming the compensation judge’s denial of excess attorney fees under the Irwin factors.The Minnesota Supreme Court affirmed the decision of the WCCA, upholding the denial of the $4,000 in excess attorney fees. View "Jurgensen vs. Dave Perkins Contracting, Inc." on Justia Law

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