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Weber v. Industrial Molded Rubber Products3/23/1999
This opinion will be unpublished and may not be cited except as provided by Minn. Stat. § 480A.08, subd. 3 (1998).
Reversed and remanded
Appellant Beth Weber challenges the district court's adverse judgment on her retaliatory discharge claim, contending that an employee cannot release an employer from retaliatory discharge liability in a workers' compensation settlement. We conclude that although the district court had jurisdiction to consider whether the workers' compensation settlement released respondent Industrial Molded Rubber Products/Promed from retaliatory discharge liability, the language of the release in this case does not encompass a retaliatory discharge claim as a matter of law. We reverse and remand.
FACTS
Weber began employment with Industrial on November 21, 1994. On January 31, 1995, Weber was injured and notified Industrial of her injuries. Industrial and its insurer denied liability, contending that Weber's injuries did not arise out of or in the course of her employment. On February 2, 1995, Industrial terminated Weber's employment.
On August 18, 1995, Weber filed a workers' compensation claim. In November 1996, the parties resolved the claim in a stipulation for settlement approved by a workers' compensation Judge. The settlement contained a release provision indicating that the settlement would constitute a "full, final and complete settlement of any and all past, present or future claims under the Minnesota Workers' Compensation Act."
On March 19, 1997, Weber filed a retaliatory discharge claim in district court. Industrial moved to dismiss, contending that the workers' compensation settlement released Industrial from liability for retaliatory discharge. The district court addressed Industrial's motion to dismiss as a motion for summary judgment pursuant to Minn. R. Civ. P. 56.03 and entered judgment for Industrial as a matter of law.
DECISION
On appeal from summary judgment, this court asks whether there are any genuine issues of material fact and whether the district court erred in applying the law. State by Cooper v. French, 460 N.W.2d 2, 4 (Minn. 1990). This court must view the evidence in "the light most favorable to the party against whom judgment was granted." Fabio v. Bellomo, 504 N.W.2d 758, 761 (Minn. 1993). This court reviews de novo a grant of summary judgment involving questions of law. Christensen v. Eggen, 577 N.W.2d 221, 224 (Minn. 1998). Where the parties do not dispute the material facts, this court need not defer to the district court's application of the law. Hubred v. Control Data Corp., 442 N.W.2d 308, 310 (Minn. 1989).
Minnesota law provides an employee with a cause of action for retaliatory discharge against "any person" for "intentionally obstructing" an employee who seeks workers' compensation benefits. Minn. Stat. § 176.82, subd. 1 (1998). Retaliatory discharge is a civil action "separate and independent from any penalties that might be awarded under the Workers' Compensation Act." Bergeson v. United States Fidelity & Guar. Co., 414 N.W.2d 724, 726 (Minn. 1987) (citing Kaluza v. Home Ins. Co., 403 N.W.2d 230, 234-35 (Minn. 1987)).
1. Both parties argue that the legal question of whether the workers' compensation settlement release precludes liability for the retaliatory discharge claim is controlled by Karnes v. Quality Pork Processors, 532 N.W.2d 560 (Minn. 1995). In Karnes, the supreme court held that "when a party pleads a release contained in a workers' compensation settlement as an affirmative defense in a subsequent retaliatory discharge action," the district court has jurisdiction to determine the validity and extent o
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