Minnesota Supreme Court overrules itself to declare that workers compensation law no longer bars civil rights claims in the workplace
In Daniel v. City of Minneapolis, the Minnesota Supreme Court reversed course and rejected the legal standard established 30 years ago under employment law in Karst v. F.C. Hayer Co., 447 N.W.2d 180 (Minn. 1989). Before Daniel, and for the past 3 decades, employment law in Minnesota did not allow an employee or former employee to pursue a discrimination, harassment, or retaliation claim against an employer while also pursuing a workers compensation claim. The courts rationalized this limit on enforcing workplace-related civil rights based on the idea that workers compensation law somehow provided the “exclusive” remedies for workplace-related harm.
In Daniel, the Minnesota Supreme Court corrected the analytical error that has prevented employees until now from obtaining back pay damages, emotional distress damages, and other remedies under the Minnesota Human Rights Act, Minn. Stat. §§ 363A.01, et seq., for discrimination, harassment, and retaliation in the workplace. In that case, the Minnesota Supreme Court recognized the simple and clear truth that physical harm because of a work-related accident is separate and distinct from the economic and emotional harm because of the work-related intentional act of discrimination, harassment, or retaliation.
Importantly in Daniel, the plaintiff asserted a disability discrimination claim after pursuing a workers compensation claim regarding a work-related injury that made him disabled for purposes of the discrimination claim. Nonetheless, the Minnesota Supreme ruled that the earlier workers compensation award to the plaintiff does not prevent him from pursuing his disability discrimination claim because that claim is separate and distinct from his earlier workers compensation claim. That said, the Minnesota Supreme Court also made clear in Daniel that employees and former employees cannot receive a double recovery based on this change in employment law. In particular, and to the extent a plaintiff pursues both civil rights and workers compensation claims against an employer, any given employer cannot be held responsible for the same conduct or consequences of that conduct under both civil rights law and workers compensation law.
