Justia Minnesota Supreme Court Opinion SummariesArticles Posted in Personal Injury
Sershen v. Metropolitan Council
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
Poitra v. Short
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing this insurance dispute for failure to state a claim, holding that resident-relative exclusions do not frustrate the purpose behind the abolition of interfamilial tort immunities.Appellants' son was seriously injured by a pet dog at his grandparents' residents. Appellants, on behalf of their son, filed a declaratory judgment action against Respondent after Respondent denied their claim for homeowner's insurance benefits on the basis a resident-relative exclusion in the relevant policy. In their complaint, Appellants claimed that resident-relative exclusions, inter alia, frustrate the purpose of the abolition of interfamilial tort immunities. The district court dismissed the complaint for failure to state a claim, and the court of appeals affirmed. The Supreme Court affirmed, holding that the resident-relative exclusion in the homeowner's insurance policy at issue was enforceable. View "Poitra v. Short" on Justia Law
Jepsen v. County of Pope
The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of summary judgment to Respondents and dismissing Appellant's wrongful death action on grounds of common law official immunity and vicarious official immunity, holding that the court of appeals erred.Four-year-old Eric Dean was killed by his father's girlfriend following at least seven separate reports from different sources of suspected abuse of Eric. Appellant brought this action against Pope County and three child protection workers (collectively, Respondents) alleging that the child protection workers' negligence in performing their duties under the Reporting of Maltreatment of Minors Act (RMMA), Minn. Stat. 626.556, was the proximate cause of Eric's death. The district court granted summary judgment for Respondents on immunity grounds. The court of appeals affirmed. The Supreme Court reversed, holding (1) the RMMA abrogated the defense of official immunity as to duties undertaken to comply with subdivisions 10 and 11 of section 626.556 or related rules and provisions of law; (2) statutory discretionary function immunity under Minn. Stat. 466.03, subd. 6 did not apply in this case; and (3) a genuine issue of material fact existed precluding summary judgment. View "Jepsen v. County of Pope" on Justia Law
Musta v. Mendota Heights Dental Center & Hartford Insurance Group
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
Johnson v. Darchuks Fabrications, Inc.
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
Leuthard v. Independent School District 912
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) vacating factual findings made by the workers' compensation judge regarding the reasonableness and necessity of an employee's medical treatment for work-related injuries, holding that the WCCA erred.Respondent received a Gillette-style injury to her neck and upper spine. Respondent was later notified by her former employer, Appellant, that it would no longer approve reimbursement for certain injections. A compensation judge determined that the injections were neither necessary nor reasonable. The WCCA reversed, concluding that the decision of the compensation judge was not supported by substantial evidence in the record. The Supreme Court reversed, holding that the WCCA erred in (1) vacating the workers' compensation judge's factual findings; and (2) directing the compensation judge to consider whether Respondent's case presented rare circumstances warranting an exception from the treatment parameters. View "Leuthard v. Independent School District 912" on Justia Law
Reetz v. City of Saint Paul
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the court of appeals concluding that Officer Eric Reetz was not entitled to defense and indemnification from his employer, the City of Saint Paul, when Reetz was sued for allegedly failing to detect a knife at a homeless shelter while working off duty as a private security guard, holding that the court of appeals erred.The City concluded that it was not obligated to defend and indemnify Reetz under Minn. Stat. 466.07 under the circumstances of this case. The court of appeals reversed. The Supreme Court reversed, holding (1) as a matter of law, Reetz was not "acting in the performance of the duties of the position" of a police officer when he allegedly failed to detect a knife that was banned only by the shelter's policies; and (2) therefore, the City was not required to defend and indemnify Reetz. View "Reetz v. City of Saint Paul" on Justia Law
Moore v. Robinson Environmental, Inc.
The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's complaint alleging that he witnessed Defendant's workers violate safety protocols resulting in contamination of his home, holding that Minn. Stat. 541.051 barred Plaintiff's claims.Plaintiff hired Defendant to remove a broken boiler that was insulated with asbestos and his asbestos pipe insulation. On March 12, 2014, a report confirmed Plaintiff's allegation that Defendant's workers tracked asbestos through Plaintiff's home. Plaintiff, however, did not sue Defendant until April 20, 2018. The district court dismissed the complaint on the grounds that the two-year statute of limitations in section 541.051 barred Plaintiff's claims. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff's damages arose out of the defective and unsafe condition of an improvement to real property, and therefore, the two-year statute of limitations in section 541.051, subdivision 1(a) barred Plaintiff's claims. View "Moore v. Robinson Environmental, Inc." on Justia 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
Palmer v. Walker Jamar Co.
In this wrongful death case, the Supreme Court affirmed the judgment of the court of appeals affirming the district court's grant of summary judgment for Honeywell International, holding that a claim accrues in an asbestos-related wrongful death action when the fatal disease is causally linked to asbestos.Deborah Palmer brought this action against Honeywell after her husband, Gary Palmer, died from mesothelioma. The district court dismissed the case, concluding that the statute of limitations barred Deborah's claim because she filed her action more than six years after Gary learned that exposure to asbestos had caused his mesothelioma. The court of appeals affirmed. The Supreme Court affirmed, holding (1) under DeCosse v. Armstrong Cork Co., 319 N.W.2d (Minn. 1982), wrongful death actions brought in connection with asbestos-related deaths accrue either upon the manifestation of the fatal disease in a way that it causally linked to asbestos or upon the date of death, whichever is earlier; and (2) because Deborah did not file this wrongful death action until more than six years after the claim accrued, Minn. Stat. 573.02, subd. 1 barred her claim. View "Palmer v. Walker Jamar Co." on Justia Law