Justia Injury Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The case involves an employee, Daniel Johnson, who had previously injured his back in 2005 while working for Furniture & Things, Inc. He continued to work for the company until 2011, managing his persistent back and leg pain with self-care treatments. In 2016, Johnson started working for Concrete Treatments, Inc., where he sustained another back injury in October 2018. He sought medical treatment for his worsening condition, which was diagnosed as a lumbar strain. In 2021, Johnson underwent surgery for severe spinal canal stenosis. He filed a workers’ compensation claim, seeking benefits for his 2005 and 2018 injuries and payment of outstanding medical expenses.The compensation judge found that Johnson had sustained a permanent work-related injury in October 2018 and that both the 2005 and 2018 injuries were substantial contributing factors to his need for medical care and surgery. The judge also concluded that Johnson was entitled to make a direct claim for unpaid medical expenses owed to his medical providers, who had not intervened in the proceedings. Concrete Treatments appealed the judge's findings on liability and conclusion regarding Johnson’s right to assert a direct claim for unpaid medical expenses.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge’s determination that Johnson sustained a permanent work-related injury in October 2018 and that the injury was a substantial contributing factor to his permanent low back condition and need for surgery. However, the WCCA held that Johnson could not assert a direct claim for unpaid medical expenses because his medical providers had not intervened in the proceedings.The Supreme Court of Minnesota affirmed in part and reversed in part the WCCA’s decision. The court held that Johnson is entitled to assert a direct claim for unpaid medical expenses and that the compensation judge’s findings regarding the October 2018 injury are not manifestly contrary to the evidence. The case was remanded to the WCCA to determine whether further factual findings are necessary regarding Johnson’s direct claim for unpaid medical expenses. View "Johnson vs. Concrete Treatments" on Justia Law

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The case involves a wrongful death claim filed by Judith Rygwall, the mother of Amy Rygwall, against ACR Homes, Inc. Amy, a profoundly vulnerable woman with intellectual and physical disabilities, was under the care of ACR Homes. On New Year's Eve 2015, Amy aspirated (inhaled food into her lungs) and began showing signs of respiratory distress. A member of ACR's staff was informed of these signs but did not seek immediate emergency care for Amy. Instead, she searched online for an urgent care clinic that accepted Amy's insurance with the shortest wait time. Amy's condition worsened, and she died 13 days later from related complications. Rygwall filed a wrongful-death action, asserting that ACR should have immediately called 911 upon learning of Amy's respiratory distress and that failure to do so caused Amy's death.ACR moved for summary judgment on the issue of causation. The district court granted ACR's motion, and the court of appeals affirmed. The district court concluded that Rygwall did not establish that Amy would not have died even if she had received emergency care soon after she exhibited respiratory distress and aspirated after lunch at Rise. The court of appeals agreed, reasoning that Rygwall's expert's report did not explain how Amy's treatment would have progressed had she been seen sooner or how immediate treatment would have prevented her condition from becoming fatal.The Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. The Supreme Court held that Rygwall raised a genuine issue of material fact as to whether ACR caused her daughter's death. The court concluded that based on the record, a reasonable jury could find in Rygwall's favor on the issue of causation, and therefore summary judgment for ACR was inappropriate. View "Rygwall vs. ACR Homes, Inc." on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the order of the district court granting summary judgment in favor of Defendant in this defamation case, holding that before Plaintiff may recover presumed damages, he must show that Defendant's speech was not only false but was made with actual malice.Plaintiff, a private figure, sued Defendant after a post on Defendant's social media page accused Defendant and others of sexual assault. The district court granted summary judgment for Defendant on the grounds that the speech involved a matter of public concern and was not made with actual malice. The court of appeals reversed, holding that the truth or falsity of Defendant's statement presented a genuine issue of material fact. The Supreme Court reversed, holding (1) the dominant theme of Defendant's post involved sexual assault in the context of the #MeToo movement, and therefore, her statement was entitled to heightened protection under the First Amendment; and (2) remand was required for a trial on the veracity of Defendant's speech and actual malice. View "Johnson v. Freborg" on Justia Law

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The Supreme Court dismissed this appeal from the opinion of the court of appeals affirming the decision of the district court to grant a harassment restraining order (HRO) against Appellant, holding that Appellant's challenge to the HRO did not present a justiciable controversy because it was moot.The district court concluded that Appellant had engaged in repeated incidents of harassing conduct against Respondent and issued a six-month HRO. While Appellant's appeal was pending, the HRO expired. The court of appeals affirmed, and Appellant filed a petition for further review. The Supreme Court dismissed the appeal without reaching the merits, holding that Appellant's challenge to the HRO did not present a justiciable controversy because it was moot. View "Winkowski v. Winkowski" on Justia Law

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The Supreme Court affirmed the judgment of the workers' compensation court of appeals (WCCA) affirming the findings and conclusions of the compensation judge determining that Employee was entitled to workers' compensation benefits because of her Gillette injury, holding that the WCCA's affirmance of the compensation judge's findings was not manifestly contrary to the evidence.Employee filed a claim petition alleging that she sustained a Gillette injury and sought workers' compensation benefits. The compensation judge ordered Employer to pay Employee benefits. The WCCA affirmed. The Supreme Court affirmed, holding that the WCCA's findings, including the date Employee's injury occurred, when Employee was required to notify Employer of her injury, and the calculation of Employe's post-injury earning capacity, were not manifestly contrary to the evidence. View "Schmidt v. Wal-Mart Stores, Inc." on Justia Law

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In this appeal arising out of the application of a provision of the Minnesota Workers' Compensation Act known as the "assault exception" the Supreme Court held that the assault exception applied and that Relator Deangelo Profit was not entitled to recover workers' compensation benefits under the circumstances of this case.Profit suffered serious injuries when he was attacked at his job site by a mentally ill acquaintance while he was performing his work injuries. Profit sought workers' compensation benefits under Minn. Stat. 176.021, subd. 1, which are to awarded in cases "of personal injury or death of an employee arising out of and in the course of employment." The Workers' Compensation Court of Appeals concluded that Profit was not entitled to recover benefits under the assault exception. The Supreme Court affirmed, holding that the assault exception did not apply where the assailant "intended to injure [Profit] because of personal reasons" and his acts were "not directed against the employee as an employee, or because of the employment." View "Profit v. HRT Holdings" on Justia Law

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The Supreme Court held that Claimant was not entitled to workers' compensation benefits after the date on which he no longer had a diagnosis of post-traumatic stress disorder (PTSD) by a licensed professional using the most recent edition of the Diagnostic and statistical Manual of Mental Disorders (DSM-5).From 2007 to 2020 Claimant was employed as a Mower County Deputy Sheriff. From September 25, 2019 to March 30, 2021, Claimant had a diagnosis of PTSD by a licensed professional, making him eligible for workers' compensation benefits. In this action, Claimant argued that he was entitled to benefits after March 30, 2021, the date that he no longer had a diagnosis of PTSD, because he remained disabled from a mental illness. The compensation court awarded benefits from April 1, 2020 into the present. The court of appeals reversed in part, concluding that Claimant was not entitled to benefits after March 30, 2021. The Supreme Court affirmed, holding that Claimant was not entitled to workers' compensation benefits after March 30, 2021. View "Chrz v. Mower County" on Justia Law

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The Supreme Court affirmed the ruling of Workers' Compensation Court of Appeals (WCCA) that Respondent was entitled to workers' compensation benefits, holding that Respondent was not entitled to relief on his claims on appeal.A licensed psychologist diagnosed Respondent, a former deputy sheriff for Carlton County, with post-traumatic stress disorder (PTSD). A compensation judge ruled that Respondent was not entitled to workers' compensation benefits because a subsequent psychological evaluation requested by the County resulted in a diagnosis of major depressive disorder but not PTSD. The WCCA reversed, holding (1) under Minn. Stat. 176.011, subd. 15(e), deputy sheriffs are entitled to a presumption that PTSD is an occupational disease if they present a diagnosis of PTSD, regardless of whether their employer offers a competing diagnosis; and (2) Respondent was entitled to the benefit of the presumption that he had a compensable occupational disease, and the County failed to rebut the presumption. View "Juntunen v. Carlton County" on Justia Law

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The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the rulings of the compensation judge finding that C. Jeremy Lagasse was entitled to contingent fees under Minn. Stat. 176.081, subd. 1(c) and that Larry Horton was entitled to partial reimbursement of fees under Minn. Stat. 176.081, subd. 7, holding that the WCCA incorrectly applied subdivision 1(c) in its standard of review.Horton, who was injured during his employment with Aspen Waste Systems and sought permanent partial disability (PPD) benefits through Aspen's insurer (Insurer), retained Lagasse to represent him in the matter. The compensation judge determined that Lagasse was entitled to contingent fees and that Horton was entitled to partial reimbursement of fees. The WCCA reversed. The Supreme Court reversed and remanded the case for further proceedings, holding (1) the WCCA incorrectly applied subdivision 1(c); and (2) the compensation judge and the WCCA incorrectly applied subdivision 7. View "Lagasse v. Horton" on Justia Law

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The Supreme Court reversed the decision of the district court granting summary judgment to Marvel, LLC in this negligence action, holding that an exculpatory clause purporting to release Marvel from "any and all claims" related to use of its inflatable amusement play area did not release Marvel from liability for its own negligence.Before seven-year-old Carter Justice attended a birthday party at an inflatable amusement play area owned by Marvel his mother signed a waiver of liability naming Justice. While there, Justice fell and hit his head on concrete floor, leading to several injuries. Justice sued Marvel when he turned eighteen. The district court granted summary judgment for Marvel, and the court of appeals affirmed. The Supreme Court reversed, holding that the waiver, strictly construed, did not release Marvel from liability for its own negligence. View "Justice v. Marvel, LLC" on Justia Law