Justia Minnesota Supreme Court Opinion SummariesArticles Posted in Labor & Employment Law
Koehnen v. Flagship Marine Co.
The Supreme Court held that a health care provider who did not intervene in an employee's pending workers' compensation proceeding after receiving adequate notice of the right to intervene cannot initiate a collateral attack on the compensation award under Minn. Stat. 176.271, .291 or Minn. R. 1420.1850, subp. 3B.Scott Koehnen was injured during the course and scope of his employment for Flagship Marine Company. Koehnen received chiropractic treatment from Keith Johnson. Johnson submitted his charges to the workers' compensation insurer for Koehnen's employer, but both the employer and insurer (collectively, Flagship Marine) denied liability for Koehnen's injury. When Koehnen filed a claim petition seeking workers' compensation benefits his attorney sent a notice informing Johnson of his right to intervene. Johnson, however, did not move to intervene, and the proceeding continued without him. Koehnen and Flagship Marine subsequently entered into a settlement agreement. The compensation judge approved the stipulation for settlement and issued an award on stipulation. Johnson later filed a petition for payment of medical expenses pursuant to section 176.271, .291.The compensation judge dismissed the petition, and the Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding that because Johnson chose not to intervene his petition was correctly dismissed. View "Koehnen v. Flagship Marine Co." on Justia Law
Abel v. Abbott Northwestern Hospital
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's Minnesota Human Rights Act and common-law negligence claims against a university and a hospital for race- and sex-based discrimination, holding that the district court erred in dismissing Plaintiff's employment discrimination claim under the Act and Plaintiff's common-law negligence claims.Plaintiff's claims stemmed from discrimination she allegedly experienced during a practicum program as a graduate student. The district court dismissed Plaintiff's claims under the Act as time barred and dismissed her common-law negligence claims for failure to establish that Defendants owed her a common-law duty separate from the obligations owed under the Act. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiff's employment discrimination claim under the act against Allina Health System was timely, and the district court erred in determining that Plaintiff's lack of compensation from the practicum barred her claim; (2) Plaintiff's remaining statutory discrimination claims against Defendants were time barred; and (3) Plaintiff alleged sufficient facts to maintain her common-law negligence claims. View "Abel v. Abbott Northwestern Hospital" on Justia Law
Minnesota Chamber of Commerce v. City of Minneapolis
The Supreme Court affirmed the judgment of the court of appeals reversing the district court's decision that the Minneapolis Sick and Safe Time Ordinance violated the extraterritoriality doctrine, holding that because the primary purpose and effect of the Ordinance is the regulation of sick and safe time within the City of Minneapolis, the Ordinance does not violate the extraterritoriality doctrine.The Ordinance at issue required employers to provide sick and safe time to employees who worked within the city. The district court enjoyed the City from enforcing the Ordinance against employers resident outside the City because the Ordinance violated the extraterritoriality doctrine. The court of appeals reversed, concluding that the Ordinance's primary purpose and effect was to regulate activity within the geographic boundaries of Minneapolis, and therefore, the Ordinance did not violate the extraterritoriality doctrine. The Supreme Court affirmed, holding that because the primary purpose and effect of the Ordinance is the regulation of sick and safe time within the City, the Ordinance does not violate the extraterritoriality doctrine. View "Minnesota Chamber of Commerce v. City of Minneapolis" on Justia Law
Kenneh v. Homeward Bound, Inc.
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the district court's grant of summary judgment in favor of Defendant after concluding that Plaintiff failed to allege conduct sufficiently severe or pervasive to support a claim for sexual harassment, holding that the conduct alleged by Plaintiff was sufficiently severe or pervasive for a reasonable person to find the work environment to be hostile or abusive.In granting summary judgment to Defendant, the district court determined that the conduct alleged did not meet the severe-or-pervasive standard for actionable sexual harassment based on a hostile work environment. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) Plaintiff has not presented the Court with a compelling reason to abandon the severe-or-pervasive standard for analyzing the objective component of a claim for sexual harassment under the Minnesota Human Rights Act, Minn. Stat. 363A.01-.44; and (2) considering the totality of the circumstances, Plaintiff presented sufficient evidence for a reasonable jury to decide that the complained of behavior was sufficiently severe or pervasive to substantially interfere with Plaintiff's employment or to create an intimidating, hostile, or offensive employment environment. View "Kenneh v. Homeward Bound, Inc." on Justia Law
Graco, Inc. v. City of Minneapolis
The Supreme Court affirmed the decision of the court of appeals affirming the district court's conclusion that the Minnesota Fair Labor Standards Act (the MFLSA) does not preempt the ordinance enacted by the City of Minneapolis that requires employers to pay minimum-wage rates that are higher than the rates set forth in the MFLSA, holding that district court correctly ruled that the MFLSA does not preempt the ordinance.The MFLSA establishes the minimum wage Minnesota employers must pay their employees. At issue was whether the City's ordinance requiring employers to pay minimum-wage rates higher than the rates set forth in the MFLSA was preempted by the MFLSA. The district court determined that state law does not preempt the ordinance because the MFLSA sets a floor, not a ceiling, for minimum-wage rates. The Supreme Court affirmed, holding (1) the MFLSA sets a floor, which does not prohibit, but instead permits, employers to pay the higher wage the ordinance requires; and (2) the Legislature did not intend to occupy the field of minimum-wage rates through the MFLSA. View "Graco, Inc. v. City of Minneapolis" on Justia Law
Ewing v. Print Craft, Inc.
The Supreme Court reversed the judgment of the Workers' Compensation Court of Appeals (WCCA) reversing the judgment of the compensation judge denying a qualified rehabilitation consultant's reimbursement claim for rehabilitation services provided during a period in which an employee was no longer suffering from a work-related injury, holding that the WCCA erred by imposing liability on the employer for rehabilitation services provided after the date that the employee's injury had resolved.In reversing the compensation judge, the WCCA concluded that the employer must pay for rehabilitation services until the employer filed a rehabilitation request for assistance. The Supreme Court reversed the WCCA's decision and reinstated the decision of the compensation judge, holding that the WCCA erred in concluding that the employer was required to show good cause to terminate the employee's rehabilitation services provided after the date that the employee's injury resolved. View "Ewing v. Print Craft, Inc." on Justia Law
Fish v. Ramler Trucking, Inc.
The Supreme Court affirmed the decision of the court of appeals concluding that, by the plain words of Minn. Stat. 604.02, a tortfeasor's liability to an injured employee is not reduced by the employer's fault.At issue was whether the 2003 amendment to Minn. Stat. 604.02, subd. 1 overturned the line of decisions holding that an employer liable to an injured employee under the Workers' Compensation Act and a third party liable in tort to that same employee do not have either joint or several liability. In this case, an employee was injured in the workplace. The employee and his employer settled the workers' compensation claim. The employee brought a negligence against the tortfeasor, which brought a third-party contribution claim against the employer. The jury found that the injury was caused by the employee, the employer, and the tortfeasor. The district court applied section 604.02 to reduce the net damage award to the employee by an amount proportionate to the employer's fault. The court of appeals reversed, concluding that the lower court erred in applying section 604.02 under the circumstances. The Supreme Court affirmed, holding that the tortfeasor's liability to the employee was not reduced by the fault of the employer. View "Fish v. Ramler Trucking, Inc." on Justia Law
Block v. Exterior Remodelers, Inc.
The Supreme Court affirmed the decision of the Workers' Compensation Court of Appeals (WCCA) ruling that Minn. Stat. 176.179 did not apply to Appellant's vacated workers' compensation award, holding that no mistaken compensation was paid, and thus, section 176.179 did not apply.Appellant injured his low back during the course of his employment and entered into a settlement agreement with his employer. The WCCA approved the settlement by an award. Appellant later petitioned to vacate the award, arguing that there was a mutual mistake of fact when the settlement was entered into and a substantial change in his medical condition that could not have been anticipated at the time of the award. The WCCA vacated the award based on the substantial change in Appellant's medical condition. When Appellant then filed a claim petition for additional benefits the parties disagreed as to whether Employer was entitled to a credit for the $40,000 already paid under the vacated award. The compensation judge ruled that section 176.179 did not apply and that Employer was entitled to full credit against Appellant's claim for benefits. The Supreme Court affirmed, holding because no mistake of fact or law occurred, no mistaken compensation was paid and that section 176.179 did not apply. View "Block v. Exterior Remodelers, Inc." on Justia Law
Alby v. BNSF Railway Co.
In this case brought under the Federal Employers' Liability Act (FELA), 45 U.S.C. 51-60, the Supreme Court reversed the decision of the court of appeals affirming the district court's use of the federal post judgment interest rate of .058 percent per year after the district court awarded Employee damages, holding that the state post judgment interest rate applies.In his complaint against his employer, BNSF Railway Company, Employee claimed that he suffered cumulative trauma to his back resulting from his twenty years of employment as a conductor and engineer. The jury decided in favor of Employee. The district court awarded damages and postjudgment interest, applying the federal postjudgment interest rate. The Supreme Court reversed and remanded the case to the district court to apply the ten percent postjudgment interest rate set forth in Minn. Stat. 549.09, subd. 1 (c)(2), holding that postjudgment interest in an action brought under FELA in Minnesota courts is calculated in accordance with Minn. Stat. 549.09, subd. 1(c). View "Alby v. BNSF Railway Co." on Justia Law
Firefighters Union Local 4725 v. City of Brainerd
The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting summary judgment to the City of Brainerd after the City restructured its fire department and eliminated all of its union positions, holding that the City engaged in an unfair labor practice prohibited by Minn. Stat. 179A.13, subd. 2(2).Firefighters Union Local 4725 and the union president sued the City under the Public Employment Labor Relations Act (PELRA), Minn. Stat. 197A.01-.25, alleging that in eliminating the union positions, the City engaged in unfair labor practices prohibited by PELRA. The district court granted summary judgment for the City. The court of appeals reversed, ruling that the City violated section 179A.13, subd. 2(2) by undergoing a department reorganization that resulted in the dissolution of a bargaining unit. The Supreme Court affirmed, holding that the City's interference with the existence of an employee organization constituted a prohibited unfair labor practice. View "Firefighters Union Local 4725 v. City of Brainerd" on Justia Law