Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part and affirming in part the district court's grant of summary judgment for Defendant, a school district, in this employment dispute, holding that summary judgment was properly granted on all of Plaintiff's claims.Plaintiff brought this action alleging that the suffered a hostile work environment and disparate treatment culminating in constructive discharge during her employment with Defendant. The district court granted Defendant's motion for summary judgment on both claims. The court of appeals reversed in part, concluding that Plaintiff had "presented sufficient evidence of disparate-treatment age discrimination to withstand summary judgment[.]" The Supreme Court reversed in part, holding that Plaintiff established a genuine issue of material fact as to whether she suffered an adverse employment action in the form of constructive discharge. View "Henry v. Independent School District #625" on Justia Law

The Supreme Court affirmed the ruling of Workers' Compensation Court of Appeals (WCCA) that Respondent was entitled to workers' compensation benefits, holding that Respondent was not entitled to relief on his claims on appeal.A licensed psychologist diagnosed Respondent, a former deputy sheriff for Carlton County, with post-traumatic stress disorder (PTSD). A compensation judge ruled that Respondent was not entitled to workers' compensation benefits because a subsequent psychological evaluation requested by the County resulted in a diagnosis of major depressive disorder but not PTSD. The WCCA reversed, holding (1) under Minn. Stat. 176.011, subd. 15(e), deputy sheriffs are entitled to a presumption that PTSD is an occupational disease if they present a diagnosis of PTSD, regardless of whether their employer offers a competing diagnosis; and (2) Respondent was entitled to the benefit of the presumption that he had a compensable occupational disease, and the County failed to rebut the presumption. View "Juntunen v. Carlton County" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the rulings of the compensation judge finding that C. Jeremy Lagasse was entitled to contingent fees under Minn. Stat. 176.081, subd. 1(c) and that Larry Horton was entitled to partial reimbursement of fees under Minn. Stat. 176.081, subd. 7, holding that the WCCA incorrectly applied subdivision 1(c) in its standard of review.Horton, who was injured during his employment with Aspen Waste Systems and sought permanent partial disability (PPD) benefits through Aspen's insurer (Insurer), retained Lagasse to represent him in the matter. The compensation judge determined that Lagasse was entitled to contingent fees and that Horton was entitled to partial reimbursement of fees. The WCCA reversed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the WCCA incorrectly applied subdivision 1(c); and (2) the compensation judge and the WCCA incorrectly applied subdivision 7. View "Lagasse v. Horton" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that decisions made under Minn. Stat. 43A.33 are quasi-judicial administrative decisions subject to certiorari review by the court but reversed its holding that the Bureau of Mediation Services was a proper party to the appeal, holding that the Bureau was not a proper party to the certiorari appeal.When the Minnesota Department of Corrections sought certiorari review of an arbitrator's decision granting Appellant's appeal from the discharge of his employment at the Minnesota Department of Corrections, Appellant challenged the court of appeals' jurisdiction to hear the appeal, arguing that review must be undertaken by the district court. The court of appeals upheld the arbitrator's decision. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant and the Department were not parties to an arbitration agreement that invoked the judicial review procedures of the Uniform Arbitration Act; (2) the decision of an arbitrator appointed according to section 43A.33 is a quasi-judicial determination of an inferior tribunal reviewable via writ of certiorari at the court of appeals; and (3) the Bureau was not a proper party to this appeal because it had no legal or equitable interest in the outcome. View "Minn. Department of Corrections v. Knutson" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming the decision of the compensation judge finding that Respondent sustained an occupational disease of hearing loss and ordering Relator to pay medical benefits under Minn. Stat. 176.135, subd. 5, holding that further proceedings were required.Respondent developed hearing loss after a career of handling occupational safety and health compliance and monitoring workplace noise levels. Respondent filed a claim for workers' compensation benefits against Relator, his most recent employer. The compensation judge ruled in favor of Respondent and denied his claim for permanent partial disability (PPD) benefits. The WCCA affirmed and clarified that the PPD issue was moot because of a Pierringer settlement between Respondent and one of his former employers. The Supreme Court remanded the case, holding (1) the occupational disease finding was supported by the evidence; (2) the award of medical benefits was appropriate under Minn. Stat. 176.135, subd. 5; and (3) the compensation judge did not properly apply the Pierringer settlement precedent, potentially prejudicing Relator's interests. View "Sershen v. Metropolitan Council" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State of Minnesota Department of Natural Resources (DNR) and dismissing Plaintiff's complaint alleging a violation of the Minnesota Whistleblower Act, Minn. Stat. 181.932, subd. 1(1), holding that there was no error.After Plaintiff, a former regional director with DNR, was terminated she brought this action alleging that her reporting of suspected illegal activity at a hotel where she was staying for a work-related conference caused her termination. The district court granted summary judgment for DNR. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Plaintiff failed to establish a genuine issue of material fact for trial over whether her alleged protected activity was a motivating factor in the decision of the DNR to terminate Plaintiff; and (2) therefore, summary judgment was properly granted. View "Hanson v. State, Department of Natural Resources" on Justia Law

The Supreme Court reversed in part the decision of the court of appeals affirming in part and reversing in part the judgment of the district court granting the Attorney General's motion to compel responses to a civil investigative demand, holding that the demand must be narrowed and that the court of appeals erred in limiting the scope of the demand.The Attorney General issued the demand at issue under Minn. Stat. 8.31 to Madison Equities, Inc. and nine of its subsidiary and related companies (collectively, Madison Group) to investigate allegations of wage theft. The Madison Group sought a protective order from the district court, arguing that the demand was overbroad. The Attorney General, in turn, moved to compel responses to the demand. The district court denied the Madison Group's motion and granted the Attorney General's motion. On appeal, the court of appeals limited the demand to information related to security guards from only four of the Madison Group entities. The Supreme Court reversed in part and remanded the case, holding that the court of appeals (1) correctly determined that the definition of "worker" in the demand must be narrowed; and (2) erred in limiting the scope of the demand to certain of the companies. View "Madison Equities, Inc. v. Office of Attorney General" on Justia Law

The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) upholding a compensation judge's order requiring Employer to reimburse Employee for medical cannabis, holding that the WCCA erred.Employee was injured while working for Employer. After multiple rounds of medical intervention proved to be unsuccessful, Employee's doctor certified her for participation in the state's medical cannabis program. Employee sought reimbursement for the cost of the cannabis from Employer. Employer asserted in response that the federal prohibition in the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, on the possession of cannabis preempted the requirement under Minnesota law that an employer pay for an injured employee's medical treatment when that treatment is medical cannabis. The WCCA declined to address the preemption argument and upheld the compensation judge's order. The Supreme Court reversed, holding (1) the WCCA lacked subject matter jurisdiction to determine the preemption issue; and (2) the CSA preempted the compensation court's order mandating Employer to pay for Employee's medical cannabis. View "Musta v. Mendota Heights Dental Center & Hartford Insurance Group" on Justia Law

The Supreme Court reversed the decision of the workers' compensation court of appeals (WCCA) affirming the decision of the compensation judge granting Respondent's claim petition seeking reimbursement from his former employer for the cost of medical cannabis, holding that the WCCA erred.At issue before the Supreme Court was whether the WCCA correctly concluded that it lacked subject matter jurisdiction to decide arguments that require interpreting federal law and whether the federal Controlled Substances Act (CSA), 21 U.S.C. 801-971, preempts the requirement in Minnesota law for an employer to reimburse an injured employee for the cost of medical treatment, Minn. Stat. 176.135, subd. 1(a). The Supreme Court held (1) the WCCA lacked subject matter jurisdiction to decide whether the relevant federal law preempted the relevant Minnesota law in this case; and (2) the CSA preempted the compensation court's order mandating Relators to pay for Respondent's medical cannabis. View "Bierbach v. Digger's Polaris" on Justia Law

The Supreme Court reversed the judgment of the Workers' Compensation Court of Appeals (WCCA) affirming the determination of the compensation judge that Respondent's treatment with opioid medication for a work-related ankle injury that resulted in a pain condition was compensable as a rare case exception, holding that the rare case exception to the treatment parameters did not apply.The opioid medication in this case was non-compliant with the long-term opioid medication parameter promulgated by the Department of Labor & Industry for that form of treatment. At issue was whether the medication was compensable under the workers' compensation laws as a "rare case" exception. The Supreme Court held that the rare case exception did not apply because the circumstances of this case were not exceptional and thus reversed the decision of the WCCA. View "Johnson v. Darchuks Fabrications, Inc." on Justia Law