Justia Minnesota Supreme Court Opinion Summaries

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

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

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

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

Appellant was discharged after testing positive to a drug test. Nearly three years after being discharged, Appellant filed an action against Respondents, his former employers, alleging that Respondents violated various provisions of the Drug and Alcohol Testing in the Workplace Act, namely Minn. Stat. 181.953. Respondents filed a motion to dismiss, asserting that Appellant's claim was barred by the two-year statute of limitations in Minn. Stat. 451.07(1) for, inter alia, libel, slander, "or other tort resulting in personal injury." The district court granted the motion, concluding that a claim under section 181.953(10) was a "tort resulting in personal injury." The court of appeals affirmed. The Supreme Court reversed, holding (1) Appellant's claim was subject to the six-year statute of limitations under Minn. Stat. 541.05(1)(2) as a cause of action "upon liability created by statute"; and (2) therefore, Appellant's complaint was not time-barred. Remanded. View "Sipe v. STS Mfg., Inc." on Justia Law

Employees filed a complaint against two employers (Employers), alleging that Employers violated the Minnesota Human Rights Act (MHRA) based on sexual harassment perpetrated by the sole owner of both entities (Owner). Employees also alleged that Owner was individually liable under MHRA's aiding and abetting provision. The district court dismissed Employees' claims. The court of appeals reversed, holding (1) the district court's determination that the harassment was not actionable was clearly erroneous, (2) Employees were entitled to judgment on their claims as a matter of law, and (3) Owner could not be individually liable for aiding and abetting Employers' MHRA violations. The Supreme Court reversed, holding (1) the court of appeals did not err in concluding that Owner could not be liable on an aiding and abetting theory; but (2) two separate errors of law infected the district court's determination that Employees did not prove their sexual harassment claims, and therefore, the Court was unable to ascertain exactly how the errors impacted the court's decision to dismiss Employees' claims. Remanded to the district court to reevaluate the evidence using the correct legal standard. View "Rasmussen v. Two Harbors Fish Co." on Justia Law

In 2002, Employee suffered injuries in a work-related accident and was rendered a paraplegic. Employer and its insurer accepted liability for Employee's injuries and paid various workers' compensation benefits. In 2010, Employee filed a medical request seeing payment for the installation of a ceiling-mounted motorized lift system. A compensation judge (1) determined that the cost of making the structural changes was compensable under Minn. Stat. 176.135 because those changes were necessary to provide Employee with reasonable and necessary medical treatment, and (2) ordered Employer and its insurer to pay for the modifications in their entirety. The workers' compensation court of appeals reversed, concluding that the changes to Employee's home necessary to permit installation of the lift system constituted "alteration or remodeling" of Employee's home and that Employer's liability was therefore limited by Minn. Stat. 176.137. The Supreme Court affirmed, holding that the cost of the structural modifications to Employee's residence that were necessary to permit the ceiling-mounted track system to be installed were "alteration or remodeling" costs subject to section 176.137 and were not costs of medical treatment. View "Washek v. New Dimensions Home Health & State Fund Mut. Ins. Co. " on Justia Law