Justia Minnesota Supreme Court Opinion Summaries

Respondent suffered a work-related back injury. Respondent and her employer entered into a “full, final, and complete” settlement of Respondent’s claims for workers’ compensation benefits related to that injury. Respondent later filed a claim petition seeking additional benefits for the back injury, alleging a lumbar spine injury with consequential depression and anxiety. The employer moved to dismiss the petition on the ground that Respondent was first required to bring a motion to vacate the existing settlement agreement before bringing a new claim. The workers’ compensation judge denied the motion, concluding that the settlement agreement did not foreclose a later claim for consequential psychological injury. The Workers’ Compensation Court of Appeals affirmed, concluding that the settlement agreement did not foreclose claims from the same incident that were not mentioned in the agreement without evidence that those claims were contemplated by the parties at the time they entered into the agreement. The Supreme Court reversed, holding that the language of the settlement agreement was sufficient settle conditions and complications that arise out of, and are a consequence of, Respondent’s workers’ compensation injury. View "Ryan v. Potlatch Corp." on Justia Law

At issue in this case was whether truck drivers hauling asphalt cement from a commercial oil refinery to a contractor’s facility are performing “work under a contract” under Minn. Stat. 177.44(1) and, therefore, must be paid prevailing wages. The Minnesota Department of Transportation (MDOT) determined that the construction companies that were awarded contracts to work on state highway projects violated the project contracts by failing to ensure that drivers that assisted in the acquisition and transport of asphalt cement for the projects were paid prevailing wages. Appellants argued that the hauling activities of these drivers did not constitute “work under a contract” under Minn. Stat. 177.44(1) and, alternatively, that the hauling activities were exempt from the prevailing wage requirements under the “commercial establishment exception” in the Prevailing Wage Act. The district courts granted summary judgment to MDOT. The court of appeals affirmed. The Supreme Court reversed, holding that hauling activities must be to, from, or on the site of a public works project to qualify as “work under a contract,” and therefore, the hauling activities in this case did not constitute “work under the contract” subject to the prevailing wage requirements. View "J.D. Donovan, Inc. v. Minn. Dep’t of Transp." on Justia Law

Kelly Dennis was allegedly injured in the course of his employment with The Salvation Army. Dennis filed a claim for workers’ compensation benefits, but The Salvation Army and its insurer (collectively, Relators) denied liability. The compensation judge awarded Dennis benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed. Within thirty days, Relators filed a petition for a writ of certiorari with the clerk of the appellate courts. Relators, however, failed to serve a cost bond on the WCCA as required by Minn. Stat. 176.471. Relators subsequently served an untimely cost bond on the WCCA. At issue before the Supreme Court was whether timely service of the cost bond was mandatory to have the WCCA order reviewed by the Supreme Court on certiorari. The Supreme Court discharged the writ of certiorari and dismissed the appeal, holding that Relators’ failure to file the cost bond within the thirty-day period to appeal was fatal to their appeal. View "Dennis v. Salvation Army" on Justia Law

Employee was injured while participating in an annual employee-recognition event sponsored by Employer. Employee petitioned for workers’ compensation benefits, but Employer denied liability, arguing that Employee’s injury was excluded from coverage under Minn. Stat. 176.021(9), which exempts from workers’ compensation coverage injuries incurred during “voluntary recreational programs.” A compensation judge concluded that the employee-recognition event was not a “voluntary” program because it occurred during Employee’s shift, and he was required to attend in order to obtain his wage without sacrificing his vacation time. The Workers’ Compensation Court affirmed. The Supreme Court affirmed, holding (1) an employer-sponsored recreational program is not “voluntary” when it takes place during work hours and employees must either attend the event or risk forfeiting pay or benefits; and (2) the relevant inquiry when applying section 176.021(9) is whether the program is voluntary, not whether individual recreational activities within the program are voluntary. View "Shire v. Rosemount, Inc." on Justia Law

Respondent fell and was injured during the course of his employment with The Salvation Army. A workers compensation judge awarded Defendant benefits, and the Workers’ Compensation Court of Appeals (WCCA) affirmed the findings and order of the compensation judge. Relators subsequently filed a timely petition for a writ of certiorari with the clerk of the appellate courts. Relators’ filing, however, did not include a cost bond. The clerk provided Relators with a conformed writ, which Relators served on Respondent and the WCCA. The WCCA notified the clerk of court that Relators had not served a cost bond on the WCCA as required by Minn. Stat. 176.471(3). Relators then served a cost bond on the WCCA. Respondent argued that the plain and unambiguous language of section 176.471 required timely service of a cost bond to effect the Supreme Court’s review. The Supreme Court held that because Relators did not timely serve a cost bond upon the WCCA as required by section 176.471(3) the writ of certiorari must be discharged and the appeal dismissed. View "Dennis v. The Salvation Army" on Justia Law

Terry Boyd filed this lawsuit against BNSF Railway Company, his former employer, under the Federal Employers’ Liability Act (FELA) after being injured in the course of his employment. Boyd later made a settlement offer, which BNSF rejected. The jury returned a verdict and award against BNSF. The district court ordered BNSF to pay double costs to Boyd pursuant to Minn. R. Civ. P. 68.03(b)(2), which provides for additional costs and disbursement incurred after an offer is rejected by a defendant and the relief awarded is less favorable to the defendant than the rejected offer. BNSF sought review, arguing that an award of double costs under Rule 68.03(b)(2) is preempted by FELA. The court of appeals affirmed. The Supreme Court reversed, holding that because double costs are substantive, rather than procedural, and are not authorized by federal law, FELA preempts the application of Rule 68.03(b)(2) in a state court FELA action. View "Boyd v. BNSF Railway Co." on Justia Law

Plaintiff, a former employee of the Minneapolis Public Schools (MPS), was notified on April 22, 2008 that her position would be eliminated. Plaintiff’s last day of work was June 30, 2008. Plaintiff commenced this lawsuit against MPS on June 29, 2010, asserting retaliation in violation of the Minnesota Whistleblower Act (MWA). The district court dismissed Plaintiff’s MWA claim on statute of limitations grounds. The court of appeals reversed, concluding that Plaintiff’s claim was subject to a six-year limitations period, as provided by Minn. Stat. 541.05(1)(2). On appeal, MPS argued that Plaintiff’s claim was subject to the two-year limitations period found in Minn. Stat. 541.07(1). The Supreme Court affirmed, holding that Plaintiff’s cause of action was governed by the six-year statute of limitations found in section 541.05(1)(2). View "Ford v. Minneapolis Public Schools" on Justia Law

After Employee ended his employment with Employer he applied for and received state unemployment benefits from the Department of Employment and Economic Development (DEED) and supplemental unemployment benefits (SUB) through a plan offered by Employer. DEED determined that the SUB plan payments counted as “wages” under Minn. Stat. 268.035(29)(A) and determined that Employee had been overpaid state unemployment benefits. An unemployment law judge affirmed. The court of appeals reversed, concluding that Employee was entitled to keep the state unemployment benefits. The Supreme Court affirmed, holding the SUB plan payments Employee received were not “wages” for purposes of his eligibility for state unemployment benefits, and therefore, Employee was not overpaid state unemployment benefits. View "Engfer v. Gen. Dynamics Advanced Info. Sys., Inc." on Justia Law

Respondent sustained injuries while employed by Employer. In 2010, Respondent sought workers’ compensation benefits, claiming that as a result of his injury he developed complex regional pain syndrome (CRPS) and that he was entitled to compensation for certain medical expenses, including expenses incurred for the implantation of a spinal cord neurostimulator. The compensation judge concluded that Respondent had failed to show that the effects of his work-related injury included CRPS and therefore necessitated a neurostimulator. The Workers’ Compensation Court of Appeals (WCCA) affirmed. In 2013, Respondent filed a second request for medical benefits seeking compensation for the expenses related to the replacement of his neurostimulator. The compensation judge dismissed the claim, concluding that Respondent’s 2013 claim was barred by res judicata and collateral estoppel. The WCCA reversed. The Supreme Court vacated the decision of the WCCA, holding (1) res judicata did not preclude Respondent’s 2013 claim; but (2) in resolving the 2013 claim, the compensation judge did not determine whether Respondent’s medical condition had changed or new material facts had emerged, a determination that was necessary in order to resolve whether collateral estoppel precluded the 2013 claim. Remanded. View "Mach v. Wells Concrete Prods. Co." on Justia Law

Yer Sumner was injured when she fell while working for Jim Lupient Infiniti. Sumner filed a claim petition for workers’ compensation benefits. Lupient denied primary liability. After Sumner filed her claim petition, eleven entities (collectively, Intervenors), including two health-care providers that provided treatment to Sumner (collectively, Relators), moved to intervene as of right. Lupient objected to the compensability of the services for which several Intervenors, including Relators, sought reimbursement. Intervenors had their claims for reimbursement denied when they failed to attend a hearing before a compensation judge. Relators and Sumner appealed. The Workers’ Compensation Court of Appeals affirmed the denial of Relators’ reimbursement claims. The Supreme Court affirmed, holding that, because Relators were absent from the hearing, and none of the exceptions to the attendance requirement was met, the compensation judge did not err when he denied Relators’ claims for reimbursement. View "Sumner v. Jim Lupient Infiniti" on Justia Law