The Minnesota Supreme Court held last week in Daniel v. City of Minneapolis that the exclusivity provision1 in the Minnesota Workers’ Compensation Act (“MWCA”) does not bar an employee’s disability discrimination claims brought under the Minnesota Human Rights Act (“MHRA”).2 In reaching its decision in Daniel, the Court overruled its own decision rendered 30 years ago in Karst v. F.C. Hayer Co.3
Under the MWCA, employees who sustain workplace injuries may be entitled to recover workers’ compensation benefits. However, the MWCA’s exclusivity provision generally prevents employees from recovering additional damages from their employers through personal injury lawsuits that pertain to workplace injuries.
But, the Court in Daniel carved an exception to the exclusivity concept by holding that the MWCA’s exclusivity provision does not bar employees from filing civil actions against their employers on a theory of disability discrimination.4
In Daniel, the plaintiff, Keith Daniel (“Daniel”), injured his right ankle while employed by the Minneapolis Fire Department (the “Department”). Daniel applied for and received workers’ compensation benefits. He also was prescribed with shoes designed to reduce pain and improve ankle stability.
About two months after being prescribed the footwear, Daniel’s deputy chief determined that the prescription shoes did not comply with the Department’s uniform policy and ordered Daniel to stop wearing the shoes. After Daniel returned to wearing the “station’s shoes” (i.e., the standard shoes issued to firefighters), he complained to the Department about his ankle swelling and the exacerbation of existing ankle pain. Daniel later reinjured his ankle and seriously injured his shoulder when he lost his footing while climbing down from a fire truck.
The Department and Daniel repeatedly discussed a type of shoe that would comply with the Department’s uniform policy, but they never reached an agreement. Eventually, the Department advised Daniel that if he wished to receive workers’ compensation benefits and continue his employment, he would need to comply with the uniform policy.
Daniel responded to the Department’s position by suing the City of Minneapolis (the “City”) in December 2015. He pursued claims under both the MWCA and MHRA. Daniel alleged that the City violated the MWCA by threatening to terminate his workers’ compensation benefits if he complied with his doctor’s prescription. He claimed that the City also violated the MHRA by forbidding his reasonable disability-based accommodation of wearing the doctor-prescribed shoes and by retaliating against him for seeking an accommodation.
Daniel agreed to settle his workers’ compensation claim and accepted early retirement. The City then moved for summary judgment on Daniel’s MHRA claim. The City argued, in part, that the MWCA’s exclusivity provision barred Daniel’s cause of action under the MHRA.
The trial court in Daniel held that claims arising under the MHRA did not conflict with the exclusivity provision under the MWCA and denied the City’s motion for summary judgment. The Minnesota Court of Appeals reversed. It ruled that the trial court lacked subject matter jurisdiction over Daniel’s MHRA claim because the MWCA’s exclusivity provision barred that claim. The Minnesota Supreme Court reversed the Court of Appeals and effectively affirmed the trial court’s order.
The Supreme Court’s holding turned on how the MWCA and MHRA exist to protect employees from distinct types of injuries. The MWCA ensures that after employees sustain physical injuries that arise out of and during the course of their employment, employees may obtain compensation for lost wages and reimbursement for medical expenses and treatments. The MHRA—as a civil rights statute—protects employees from their employers taking discriminatory action against them based on a protected status and allows potential recovery for a broad range of monetary damages, as well as civil penalties.
In Daniel, the civil rights claim focused on whether the Department intentionally violated Daniel’s right to a reasonable accommodation because of his disability. In other words, the civil rights claim was completely distinct from any claim for compensation related financial or medical losses arising from a work-related injury under the MWCA. In issuing this decision, the Minnesota Supreme Court explicitly overruled its own prior case, Karst v. F.C. Hayer Co. In Karst, the Minnesota Supreme Court held that the MWCA’s exclusivity provision barred the employee’s claims for disability discrimination under the MHRA.
The decision in Daniel is likely to change the legal landscape when employers are faced with dual claims under the MWCA and MHRA. Employers should no longer expect a dismissal of MHRA claims by virtue of the MWCA’s exclusivity provision. Though, in some cases, employers may nonetheless find success in limiting damages. In Daniel, the Minnesota Supreme Court re-affirmed the longstanding principle that employees cannot receive double recovery for the same harm. In other words, even though employees may bring concurrent claims under the MWCA and MHRA, they cannot recover damages twice for the same injury. To that end, the Minnesota Supreme Court appeared amenable to a trial court deducting the amount of workers’ compensation benefits received by the employee from any subsequent award of damages in a civil suit brought under the MHRA.
If you have any questions regarding this content or other employment law trends, please contact the authors or one of the other attorneys in HKM’s Employment Law Group at (651) 227-9411.