Justia Minnesota Supreme Court Opinion Summaries

Relator was injured while working for Employer. Relator began receiving workers’ compensation benefits in 2010. In 2012, Relator began receiving a retirement annuity from the Public Employees Retirement Association (PERA). At some point, Relator began receiving federal social security retirement benefits. While Employer was entitled under Minn. Stat. 176.101(4) to offset Relator’s permanent total disability benefits by the amount of her social security retirement benefits, the parties disagreed as to whether Employer was entitled to apply the offset to Relator’s PERA retirement benefits. A compensation judge granted Employer the offset. The Workers’ Compensation Court of Appeals (WCCA) affirmed, concluding that Relator’s PERA retirement annuity was an “old age and survivor insurance benefit.” The Supreme Court reversed, holding that, under the reasoning in Ekdahl v. Independent School District #213, also decided today, section 176.101(4) does not permit permanent total disability benefits to be offset by public employee pension benefits. Remanded. View "Hartwig v. Traverse Care Ctr." on Justia Law

Relator was injured while working for a School District. Relator eventually sought and was awarded permanent total disability (PTD) benefits. Relying on Minn. Stat. 176.101(4) and claiming that the statute authorizes an offset for “any old age and survivor insurance benefits,” the School District sought to offset its PTD benefit payment by the amount of government-service pension benefits Relator was receiving. A compensation judge concluded that the School District was not entitled to the offset. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that government-service pension benefits are included in the phrase “old age and survivor insurance benefits” and therefore can be offset from the School District’s disability-benefit payment. The Supreme Court reversed the WCCA and reinstated the decision of the compensation judge, holding that the phrase “old age and survivor benefits” refers only to federal social security benefits, and therefore, the WCCA erred when it applied section 176.101(4) to Relator’s retirement annuity. View "Ekdahl v. Indep. Sch. Dist. #213" on Justia Law

Employee was injured in a work-related accident. Employee obtained approval for surgery from a union-sponsored benefit plan (the Fund) and proceeded with the surgery at a Hospital. After a hearing, a workers’ compensation judge concluded that the surgery was not reasonable and necessary and ordered Employer to reimburse the Fund for the medical bills but also concluded that Employer could seek reimbursement of the expenses from the medical providers. The Hospital was not given notice of that hearing. Before a second hearing on Employer’s request for reimbursement, the Hospital intervened. The compensation judge ordered the Hospital to reimburse Employer. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that the automatic-reimbursement rule announced in Brooks v. A.M.F., Inc. should be extended to the Hospital because it was not given notice of the first hearing. The Supreme Court reversed after declining to extend its decision in Brooks and require automatic payment of a medical provider’s treatment expenses when an employer fails to give the medical provider notice of its right to intervene in a workers’ compensation proceeding to determine responsibility for those expenses, holding that the Hospital was not entitled to automatic payment of its medical bills for Employee’s treatment. Remanded. View "Gamble v. Twin Cities Concrete Prods." on Justia Law

The State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights. View "State v. Little" on Justia Law

The Chief Deputy of the Steele County Sheriff’s Office evaluated the performance of Respondent, a sergeant, and gave him a negative review. Respondent appealed the Sheriff’s decision with the Minnesota Department of Administration by submitting a statement explaining why he disagreed with portions of the performance evaluation. The Department summarily dismissed the administrative appeal. The court of appeals reversed and remanded the case for informal resolution or a contested-case proceeding under the Data Practices Act (Act). The Supreme Court affirmed, holding (1) the Department wrongly concluded that Respondent’s appeal categorically fell outside the scope of the Act; (2) there was no support for the Department’s argument that dismissal was proper because the appeal raised new challenges and relied on new evidence; and (3) the Department does not have unqualified and unreviewable authority to dismiss any appeal brought under the Act. View "Schwanke v. Minn. Dep’t of Admin." on Justia Law

Appellant was convicted for the first-degree premeditated murder of Devan Hawkinson. Appellant and Hawkinson were friends before Hawkinson was murdered. On appeal, Appellant argued that the district court erred by admitting evidence of his past conduct and relationship with Hawkinson, contending that the evidence violated his rights under the Confrontation Clause because it included testimonial statements that Hawkinson made to the police before his death and that it was irrelevant. The Supreme Court affirmed, holding (1) any error in admitting the evidence was harmless; and (2) none of the claims raised in Appellant’s pro se briefs entitled him to relief. View "State v. Rossberg" on Justia Law

The question presented in this case was whether the plausibility standard announced in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal applies to civil pleadings in Minnesota state court. Defendant in this case moved to dismiss Plaintiff’s complaint pursuant to Minn. R. Civ. P. 12.02(e) for failure to state a claim upon which relief can be granted, alleging that the complaint failed to allege enough facts to state a plausible claim. Using the Twombly plausibility standard, the district court dismissed Plaintiff’s complaint with prejudice, concluding that Plaintiff failed to establish facts giving rise to a plausible claim for relief. The court of appeals reversed after applying the state’s traditional pleading standard. The Supreme Court affirmed, holding (1) the Twombly plausibility standard does not govern civil pleadings in Minnesota; and (2) Plaintiff’s complaint satisfies the traditional pleading standard for civil actions in Minnesota. View "Walsh v. U.S. Bank, N.A." on Justia Law

Appellant pleaded guilty to one count of aiding and abetting first-degree premeditated intentional murder. The district court sentenced Appellant to a mandatory life sentence with the possibility of release after thirty years. More than eight years after Appellant was sentenced, the district court issued its restitution order, which ordered that Defendant be jointly and severally liable for paying $23,060 in restitution along with several of his codefendants. The Supreme Court affirmed in part, vacated in part, and remanded, holding (1) Defendant forfeited his argument that the restitution order improperly included restitution for losses for which an insurance company had already reimbursed the victim’s estate; (2) the order improperly calculated the restitution Appellant and his codefendants should pay for damage done to the victim’s car; and (3) the district court had statutory authority to order that the codefendants were jointly and severally liable for the restitution award. View "State v. Johnson" on Justia Law

In 1984 and 1985, James Stevens injured both shoulders while working for S.T. Services and CNA Insurance Companies (collectively, S.T. Services). In 1994, Stevens and S.T. Services entered into a stipulation for settlement under which the parties agreed that Stevens was permanently totally disabled and would receive ongoing permanent total disability benefits. A compensation judge entered an award on the stipulation, and Stevens received benefits until 2011. Stevens began working as a plumbing specialist in 2008 and disclosed his job to S.T. Stevens but continued to receive workers’ compensation benefits. In 2011, S.T. Services filed a petition with the Workers Compensation Court of Appeals (WCCA) to discontinue paying benefits on the grounds that Stevens was no longer permanently totally disabled. A compensation judge granted S.T. Services’ petition to discontinue, and the WCCA affirmed. The Supreme Court reversed, holding that S.T. Services was not allowed by statute to file a petition to discontinue benefits under the circumstances of this case. View "Stevens v. S.T. Servs." on Justia Law

Employee filed an amended complaint seeking indemnity benefits and medical benefits from compensable injuries to his spine. Employee, however, decided not to pursue his indemnity claims at the compensation hearing. The compensation judge found that Respondent had sustained a Gillette injury to his spine and awarded him medical benefits. Employee subsequently sought reimbursement from Employer for attorney fees under Minn. Stat. 176.081. The compensation judge concluded that Employee was entitled to attorney fees under the statute. Employer appealed, arguing that to be eligible for attorney fees, section 176.081 requires an employee to address all related issues at the same time, and so when Employee pursued only a claim for medical benefits, he forfeited his statutory right to all attorney fees. The Supreme Court affirmed, holding that the compensation judge in this case followed the appropriate legal framework in determining the attorney fee award and did not abuse his discretion in the amount awarded. View "Braatz v. Parsons Elec. Co." on Justia Law