In Karst v. F.C. Hayer Company, the Minnesota Supreme Court held an employee who received workers’ compensation benefits for work-related injuries was barred from bringing a disability discrimination claim under the Minnesota Human Rights Act based on the same employer’s unwillingness to rehire him. 447 N.W.2d 180 (Minn. 1989). The Court used to the exclusivity provision of the Workers’ Compensation act limited the employee to remedies under that act.
In the case of Daniel v. City of Minneapolis, decided on February 27, 2019, when faced with a similar discrimination complaint from one if its firefighters, the City of Minneapolis attempted to rely on the language of the Karst decision to defend itself, given the “narrow” exceptions to the exclusivity clause of the act.
While the circumstances of the cases differed slightly (Karst was no longer an employee of the company, while Daniel was suing for employer conduct while he was still employed), the question to be decided remained the same: Does the exclusivity provision under the workers’ compensation act bar an employee’s claims for disability discrimination under the human rights act?
In Daniel, the Court revisited the reasoning for its earlier decision. In Karst it found that there was little information regarding the conflicting exclusivity provisions of both acts, that it was given little guidance by the legislature, and that it could only come to the conclusion that employees receiving workers’ compensation were barred from claims under the Minnesota Human Rights Act for the same injury. The Court found that the focus in Karst was inappropriately placed on the remedies available to the injured employee instead of the “nature and cause” of the injury.
In its decision to go against its own precedent, the Court held that the question of whether the exclusivity provisions of the Workers’ Compensation Act “bars an employee’s claim depends precisely upon the ‘exact nature are cause’ of the injury because the exclusivity provision…only applies if the injury is one that is covered by the act.” In other words, the injury for which the employee received workers’ compensation must be the same injury for which the employee is seeking compensation through a human rights act claim in order to be barred.
The Court held that while Daniel received workers’ compensation for his injury, he was injured in a different manner by the City in his claim under the human rights act, as that claim arose from the City’s response to his disability – a failure to accommodate his disability.
While it can be disheartening (for attorneys) to see years of precedent thrown out when a court revisits an issue that appears to have already been settled, this decision seems to make sense. Just because an employee is receiving payments for a workers’ compensation injury does not give an employer carte blanche to ignore its obligations to accommodate employees still in the workplace. Employers still need to utilize their interactive process to work with employees on accommodations.
If you have questions about your interactive process or employees working with disabilities, contact us at the Wiley Law Office, for advice that works.