Justia Minnesota Supreme Court Opinion Summaries
Articles Posted in Labor & Employment Law
Frandsen v. Ford Motor Co.
George Frandsen was employed by Ford Motor Company when he was injured in the course and scope of his employment. Ford assumed responsibility for the injury and paid Frandsen temporary total disability (TTD) benefits pursuant to the Minnesota Workers' Compensation Act. Later, the parties agreed to reclassify the TTD benefits Ford had previously paid to Frandsen as permanent total disability (PTD) benefit payments. After Frandsen turned sixty-seven years old, Ford petitioned the WCCA to discontinue payment of Frandsen's PTD benefits pursuant to Minn. Stat. 176.101, which states that permanent total disability shall cease at age sixty-seven because the employee is presumed retired from the labor market. The Workers' Compensation Court of Appeals (WCCA) denied Ford's petition, concluding that Ford had waived the retirement presumption by failing to expressly reserve the right to discontinue payment of Frandsen's PTD benefits in the settlement agreement. On review, the Supreme Court reversed the WCCA, holding (1) the retirement presumption applies unless the employee rebuts the presumption or proves knowing and intentional waiver by the employer, and (2) here the record lacked any evidence that Ford intended to continue paying PTD benefits to Frandsen after he turned sixty-seven. Remanded. View "Frandsen v. Ford Motor Co." on Justia Law
Martin v. Morrison Trucking, Inc.
Employee was injured while working in Minnesota for Wisconsin-based Employer. Employee applied for Wisconsin and Minnesota workers' compensation benefits. Employer's insurance company, Travelers Insurance, covered the Wisconsin benefits but denied the claim for Minnesota benefits based on an exclusion of Minnesota coverage in Employee's policy. Employee then filed a claim for Minnesota benefits with the Minnesota Department of Labor and Industry. After settling the claim, the Department pursued a petition for reimbursement it had filed against Employer. A compensation judge found that Employer was not insured for Minnesota workers' compensation liability and ordered Employer to reimburse the Department. The Workers' Compensation Court of Appeals (WCCA) reversed, concluding that Employer was entitled to coverage from Travelers under the reasonable expectations doctrine. On review, the Supreme Court reversed and remanded for reconsideration in light of a recent Court decision clarifying that the doctrine should not be used to provide coverage in contravention of unambiguous policy terms. On remand, the WCCA again reversed the compensation judge. On review, the Supreme Court reversed, holding that the WCCA had no authority to declare unambiguous language of an insurance contract to be invalid and unenforceable because the exclusion conflicted with Wisconsin statutory provisions and public policy. View "Martin v. Morrison Trucking, Inc." on Justia Law
Allen v. Burnet Realty, L.L.C.
While Timothy Allen worked as a sales associate for respondent Burnet Realty, he executed agreements to participate in respondent's legal administration program (LA Program). Under the LA Program contracts, Allen and respondent agreed to an allocation of expenses should a dispute arise related to Allen's work for respondent. In litigation commenced after he stopped working for respondent, Allen claimed that respondent violated Minn. Stat. 60K.47 because the LA Program contracts were insurance, and, as a result, respondent was required to be, but was not, authorized to engage in the business of insurance in Minnesota. Allen also claimed other relief on the basis that the contracts were insurance. The district court granted summary judgment in favor of respondent, concluding that the contracts were not contracts of insurance. The court of appeals affirmed. The Supreme Court affirmed the grant of summary judgment to respondent, holding that the LA Program was not "insurance" under statutory definitions on statute or case law. View "Allen v. Burnet Realty, L.L.C. " on Justia Law
City of Saint Paul v. Eldredge
William Eldredge, an honorably discharged veteran and a firefighter employed by the City of Saint Paul, was notified by the City that it intended to terminate his employment. Eldredge challenged the termination under the Veterans Preference Act (VPA), which provided that Eldredge may not be removed from his job except for incompetency or misconduct shown after a hearing. The Saint Paul Civil Service Commission granted summary disposition in Eldredge's favor. The City sought judicial review by petitioning for and securing the issuance of a writ of certiorari from the district court. The court dismissed the writ after concluding that the City had missed the filing deadline for appeals under the VPA. The court of appeals reversed. The Supreme Court affirmed the court of appeals, holding (1) the district court erred when it concluded the writ was untimely, and (2) because the writ was timely, the district court had jurisdiction to consider the City's appeal. Remanded. View "City of Saint Paul v. Eldredge" on Justia Law
Stagg vs. Vintage Place Inc.
Respondent Ronald Stagg was discharged from employment by Respondent Vintage Place, Inc. for excessive absenteeism and tardiness. Stagg applied for unemployment benefits. An unemployment law judge (ULJ) determined that Stagg was ineligible for benefits because he was discharged for employment misconduct as defined by state law. On appeal, the appellate court reversed the ULJ, holding that Vintage Place failed to follow its own disciplinary policies when it terminated Stagg. Stagg argued that he relied on the employee manual, which defined Vintage Place's formal discipline procedures. Because he had not received a ten-day suspension--the last disciplinary step short of termination under Vintage Place's policy--Stagg did not understand his job was at risk for termination. The appellate court held that Stagg could have reasonably expected Vintage Place to follow its own disciplinary policy, and that Stagg's absenteeism did not amount to denial of unemployment benefits. Given the record presented, the Supreme Court disagreed with the lower court's ruling, reversing it and reinstating the ULJ's decision.