Exclusivity Provision of Minnesota Workers’ Compensation Act Does Not Bar Claims for Discrimination

The Minnesota Supreme Court held that the exclusivity provision of the Minnesota Workers’ Compensation Act does not bar claims for disability discrimination brought under the Minnesota Human Rights Act.

In Keith Daniel v. City of Minneapolis, Daniel, a firefighter for the Minneapolis Fire Department, sued the City of Minneapolis alleging that while he was working, the City discriminated against him by failing to accommodate his disability and retaliating against him for seeking an accommodation to wear doctor prescribed tennis shoes following an ankle injury. The City moved for summary judgement, arguing that Daniel’s claims were barred by the exclusivity provision in the Minnesota Workers’ Compensation Act. The district court denied summary judgement and the court of appeals reversed.

The Minnesota Supreme Court overruled their decision in Karst and held that the exclusively provision of the Minnesota Workers’ Compensation Act does not bar claims for discrimination under the Minnesota Human Rights Act. The Court’s opinion stated “Because Daniel’s alleged injury under the human rights act arose not from his original ankle injury but from his employer’s alleged discriminatory response to that injury, his injury is not a covered injury under the workers’ compensation act. The two statutory schemes address distinct injuries. As a result, we conclude that no conflict exists between the exclusivity provisions of the workers’ compensation act and the human rights act.”

Please click here to download a copy of the Court’s decision.

If you have any questions, please contact Lauren Harvey at lnh@mccollumlaw.com.

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