Justia Minnesota Supreme Court Opinion Summaries

At the time of his divorce from Wife, Husband was a participant in a pension fund (Fund). To enforce the interest awarded to her under the decree, Wife needed to serve a domestic relations order (DRO) on the Fund and its administrators (collectively, the Plan) for qualification. Before Wife served any DRO on the Plan, Husband remarried. At the time of Husband's retirement, he made a survivor annuity payable to his current spouse upon his death. Wife eventually served a DRO on the Plan in 2005, but the Plan refused to qualify the DRO. After Husband died, Wife brought a motion to enforce the 2005 DRO. The district court ruled in favor of Wife, concluding (1) surviving spouse benefits do not vest in a plan participant's current spouse at the time of the plan participant's retirement; and (2) therefore, the 2005 DRO served on the Plan was a qualified domestic relations order. The court of appeals reversed. The Supreme Court affirmed, holding (1) under ERISA, surviving spouse benefits vest in a plan participant's current spouse at the time of the plan participant's retirement; and (2) accordingly, the 2005 DRO in this case could not be qualified. View "Langston v. Wilson McShane Corp." on Justia Law

At issue in this case was whether Appellants, who were employees of a contractor that performed work pursuant to a municipal contract with the City of Minneapolis, may recover for the contractor's alleged breach of a prevailing wage provision in the contract. Appellants brought this action against the contractor, alleging that the contractor failed to pay them the prevailing wage in breach of the contract with the City, that the breach of the contract by the contractor violated state wage statutes, and that the contractor was unjustly enriched as a result. The district court granted the contractor's motion for summary judgment, concluding that Appellants were not intended third-party beneficiaries and that without a viable claim for breach of contract, Appellants' other claims failed. The court of appeals affirmed. The Supreme Court affirmed, concluding that Appellants were not intended third-party beneficiaries of the contract and that Appellants' other claims lacked merit. View "Caldas v. Affordable Granite & Stone, Inc." on Justia Law

At issue in this case was whether the workers' compensation courts had the authority to hear a petition filed by Insured to determine whether Insurer had a duty to defend and indemnify Insured under a policy for workers' compensation insurance. Insurer moved to dismiss Insured's petition, arguing that the compensation judge did not have subject matter jurisdiction to hear the petition because it asserted a breach of contract claim rather than one arising under the workers' compensation laws. The compensation judge disagreed and denied Insurer's motion to dismiss. The workers' compensation court of appeals (WCCA) affirmed, concluding that Insured was seeking a declaration that its insurance coverage with Insurer was still "in effect," a question within the compensation judge's authority to decide. The Supreme Court affirmed, holding that the workers' compensation courts had jurisdiction to decide the issues presented in Insured's petition for declaration of insurance coverage, as the real nature of the claim was whether Insured's insurance coverage was in effect, a question that was within the authority of the compensation judge to answer. View "Giersdorf v. A & M Constr., Inc." on Justia Law

A compensation judge found Respondent was barred from receiving workers' compensation benefits because his written notice of injury, given nearly two years after his last day of work, was not timely and because Respondent's employer did not have actual knowledge that Respondent's back problems were work-related. The workers' compensation court of appeals (WCCA) reversed, concluding that a reasonable person in Respondent's position would not have known his injury was compensable until Respondent's doctors provided written reports to Respondent's attorney establishing a relationship between Respondent's back problems and his job duties. The Supreme Court reversed the WCCA and affirmed the denial of benefits, holding (1) the WCCA erred in overturning the compensation judge's finding that Respondent failed to give timely notice to his employer of his work-related injury; and (2) the compensation judge did not err in finding that the employer did not have actual knowledge of such an injury. View "Anderson v. Frontier Commc'ns" on Justia Law

Respondent brought a claim against Appellants, the University of Minnesota and Orlando Smith, the University's men's basketball coach, alleging that Smith negligently misrepresented that he had authority to hire Respondent, and that Respondent suffered damage. The jury found in favor of Respondent and awarded damages. The court of appeals affirmed. At issue on appeal was whether the Supreme Court, as a matter of public policy, should extend the protection against negligent misrepresentation to prospective employees of the University, which is a constitutional corporation and agency of the state. The Supreme Court reversed, holding that when a prospective government employment relationship is negotiated at arm's length between sophisticated business persons who do not have a professional, fiduciary, or other special legal relationship, the prospective employee is not entitled to protection against negligent misrepresentations by the representative for the prospective government employer. View "Williams v. Smith" on Justia Law

Respondent Robert Half International (RHI) terminated Appellant Kim Hansen's employment shortly after she returned from maternity leave and failed to reinstate her to the same or similar position. Hansen filed an action against RHI, alleging that it violated the Minnesota Parenting Leave Act (MPLA) and the Minnesota Human Rights Act (MHRA) by failing to reinstate her to her position or a comparable position after maternity leave, for retaliating against her for taking maternity leave, and for terminating her because of her sex. The district court granted summary judgment in favor of RHI. The court of appeals affirmed. The Supreme Court affirmed, holding that there were no genuine issues of material fact and that judgment was appropriate as a matter of law. View "Hansen v. Robert Half Int'l, Inc." on Justia Law

Appellant Carol LaMont filed suit against her employer, a school district, for violations of the Minnesota Human Rights Act (MHRA). Appellant claimed that she had been subjected to a hostile work environment based on her sex and that she had suffered sexual harassment. The district court granted summary judgment to the school district on both claims, concluding that a hostile work environment based on sex was not actionable, and even if it were, Appellant had not established that the conduct of the school district's employees was sufficiently severe or pervasive. The court of appeals affirmed. The Supreme Court affirmed but under different grounds, holding (1) a cause of action for a hostile work environment based on sex is actionable under the MHRA; but (2) Appellant's allegations were insufficient to state a claim of hostile work environment. View "LaMont v. Independent School District #728" on Justia Law

Relator Minh Nguyen was injured after falling from a ladder while employed by Audio Communications. Nguyen filed an amended petition to seek benefits for permanent total disability, but his petition did not seek to establish the date of onset of permanent disability. After a compensation judge awarded Nguyen benefits from March 4, 2008, for permanent total disability, Audio Communications petitioned the compensation judge for determination of the date of onset. The judge found that Nguyen became permanently and totally disabled as of March 1, 2007. Nguyen then petitioned to require Audio Communications to pay the attorney fees he incurred in partially succeeding in opposing Audio Communications' petition for determination of the date of onset of permanent total disability. The compensation judge denied the claim for attorney fees, and the WCCA affirmed. The Supreme Court affirmed, holding that an employer is not liable for the attorney fees incurred by an injured employee in successfully defending against the employer's petition to offset social security disability benefits paid to the employee against benefits paid by the employer for permanent total disability, where the employee's attorney fees can be paid from ongoing workers' compensation benefits paid to the employee. View "Nguyen v. Audio Commc'ns" on Justia Law

Employee was injured in a work-related accident in Minnesota and then moved to Wyoming where she received medical treatment. The Wyoming medical providers submitted their charges to Employer's workers' compensation insurer. Relying on Minn. Stat. 176.136, subd. 1b(d), the insurer made payments in the amount provided under the workers' compensation benefit structure in Wyoming. Employee filed a workers' compensation medical request for the unpaid balance, arguing that Minn. Stat. 176.135, subd. 1 was controlling. The workers' compensation judge agreed and found for Employee. The workers' compensation court of appeals reversed. The Supreme Court affirmed, holding (1) Minn. Stat. 176.136, subd. 1b(d) limits a Minnesota employer's workers' compensation liability to an out-of-state medical provider to the amounts provided in the workers' compensation schedule of benefits in the state where the provider is located; and (2) section 16.136, subd. 1b(d) was not unconstitutional as applied. View "Schatz v. Interfaith Care Ctr." on Justia Law

Appellant was employed by School District for three school years as the activities director and for one school year as interim middle school principal. Subsequently, School District terminated Appellant's employment. Appellant filed a grievance on the ground that he was a continuing-contract employee and entitled to continuing contract rights under Minn. Stat. 122A.40. School District denied the grievance. The court of appeals affirmed. At issue on appeal was whether Appellant's employment by the school district as an activities director fell within the definition of a "teacher" under section 122A.40, which would determine whether he was entitled to continuing-contract rights under the statute. The Supreme Court affirmed, holding that Appellant was not a professional employee required to hold a license from the state department and therefore was not a "teacher" within the meaning of the continuing-contract statute. View "Emerson v. Indep. Sch. Dist. 199" on Justia Law