Justia Minnesota Supreme Court Opinion Summaries

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

Appellant was denied a promotion after based on the results of a civil service test conducted by the Richfield Police and Fire Civil Service Commission. Appellant filed a petition for writ of certiorari with the Court of Appeals, arguing that the Commission’s promotional process failed to meet the requirements of Minn. Stat. 419.06(9). The Supreme Court reversed, holding (1) the Court of Appeals erred by determining that the term “records” under section 419.06(9) includes a candidate’s interview responses at the time the candidate is applying for a promotion; and (2) the Commission violated section 419.06(9) when it failed to consider records “kept in the regular course of the administration of civil service” as required by statute. View "Peterson v. Richfield Civil Serv. Comm’n" on Justia Law

Employee fractured her ankle on a staircase at her workplace. A workers’ compensation judge awarded benefits to Employee, concluding that the injuries “arose out of” her employment. The Workers’ Compensation Court of Appeals (WCCA) affirmed, relying on its previous decision in Dykhoff v. Xcel Energy. The Supreme Court stayed Employer’s appeal while it considered Dykhoff. The Supreme Court then reversed the WCCA’s decision in Dykhoff and remanded. On remand, the WCCA again affirmed, this time applying the “increased risk” test, which requires an employee to to show that her workplace exposed her to a risk of injury that was increased over what she would face in her everyday life. The WCCA relied on two factual findings to conclude that Employee’s injury was compensable under the increased risk test. The Supreme Court reversed, holding that the WCCA’s decision was manifestly contrary to the evidence. Remanded. View "Arrowhead Senior Living Cmty. v. Kainz" on Justia Law

Appellant brought an action against Respondent, a railroad company, in state court seeking damages under the Federal Employers’ Liability Act (FELA) and the Locomotive Inspection Act (LIA). The jury returned a verdict in favor of Appellant, finding that Respondent had violated LIA. Thereafter, Appellant filed a motion to amend the judgment, requesting interest from the date of the verdict to the date of judgment. The district court denied the motion on the ground that prejudgment interest is not available in a FELA action. The Supreme Court affirmed, holding that post-verdict, prejudgment interest is not available in a FELA action as a matter of federal substantive law. View "Kinworthy v. Soo Line R.R. Co." on Justia Law

In 2012, the governing board of Avera Marshall Regional Medical Center notified the hospital’s medical staff that it had approved the repeal of the medical staff bylaws and replaced them with revised bylaws. Avera Marshall’s Medical Staff, Chief of Staff, and Chief of Staff-elect commenced an action seeking a declaration that the Medical Staff had standing to sue Avera Marshall and that the former medical staff bylaws constituted a contract between Avera Marshall and the Medical Staff. The district court granted judgment for Avera Marshall and dismissed the case, concluding that the Medical Staff lacked the capacity to sue under Minnesota law and that the medical staff bylaws did not constitute an enforceable contract between Avera Marshall and the Medical Staff. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Medical Staff has the capacity to sue and be sued under Minnesota law; and (2) the medical staff bylaws constitute an enforceable contract between Avera Marshall and the individual members of the Medical Staff. Remanded. View "Medical Staff of Avera Marshall Reg’l Med. Ctr. v. Avera Marshall" on Justia Law

Minn. Stat. 176.081(1)(a) requires employers and insurers to pay attorney fees calculated by a statutory formula not subject to judicial review. In this case, Respondent injured his back while working for Employer. Employer and its insurer (together, Relators) settled with Respondent. Respondent’s attorney then sought an award of contingent attorney fees in an amount that was calculated by applying the statutory formula in section 176.081 but which disregarded the upper limit set by the formula. Relators objected, arguing that, in the absence of judicial review to ensure a fee award is not excessive, application of the statutory formula violates separation of powers principles. The compensation judge applied the statutory formula and concluded that $13,000 would adequately compensate Respondent’s attorney but refused to consider whether the statutory fee was reasonable. The Workers’ Compensation Court of Appeals affirmed the compensation judge’s fee award. The Supreme Court affirmed, holding (1) the Court will recognize the Legislature’s statutory formula as presumptively reasonable, and, absent exceptional circumstances, further judicial review of an award based on the statutory formula is unnecessary; and (2) Relators failed to present any exceptional circumstances to challenge this presumption. View "David v. Bartel Enters." on Justia Law

After Sining Mao left his employment with Seagate Technology, LLC, Mao joined Seagate’s competitor, Western Digital Corporation. Seagate subsequently commenced a district court action alleging that Mao stole Seagate’s trade secrets and confidential information and provided it to Western Digital. Western Digital invoked an arbitration clause in Mao’s employment agreement with Seagate. Before the arbitration hearing, Seagate brought a motion for sanctions against Western Digital and Mao (Appellants) based on alleged fabrication of evidence. An arbitrator issued an award against Appellants in an amount exceeding $500 million. The district court vacated the award in part, but the court of appeals reinstated the award. On appeal, Appellants argued that the arbitrator’s exceeded his authority by issuing punitive sanctions and prejudiced Appellants by refusing to hear evidence material to the controversy. The Supreme Court affirmed the court of appeals’ decision reinstating and confirming the arbitration award in full, holding that the arbitrator did not exceed his authority or refuse to hear material evidence as required for vacatur. View "Seagate Tech., LLC v. W. Digital Corp." on Justia Law