The Minnesota Supreme Court’s July 2016 decision in Ryan v. Potlatch might be perceived as a victory for employers, but all is not lost for employees who suffer job-related injuries. Employees who are at risk for those injuries, however, will need to consider this decision and to understand what Is happening In Minnesota workers’ compensation law to protect their interests and their right to receive compensation when they are injured.
The facts in the Ryan v. Potlatch case involved an employee who suffered a work-related back injury. She and her employer signed what was deemed to be a“full, final, and complete” settlement agreement of her claims. Much later after she filed that agreement, she filed a second claim for benefits relating to the injury in which she alleged that she suffered from a lumbar spine injury, and depression and anxiety related to that injury. Her employer moved to dismiss this second claim, arguing that she would need to seek to vacate her first claim before she file a second. The employer’s motion was denied by a Minnesota worker’s compensation and that denial was affirmed by the state’s worker’s compensation appellate court. Both the judge and the appellate court agreed that the initial settlement claim did not preclude later claims for damages related to the initial injury that were not mentioned in the settlement agreement and that were not considered when the parties signed that agreement.
The Minnesota Supreme Court disagreed and reversed the judge’s and the appellate court’s decision. The Supreme Court focused on the “full, final, and complete” language in the settlement agreement to support its ruling that the agreement resolved all injuries that arose out of the employee’s original injury. The Court observed that Section 176.521 of the Minnesota Statutes allows settlements that contemplate future injuries.
Employees who suffer work-related injuries can take two things away from the Supreme Court’s decision. First, employees need to take extreme care to review and to have their attorneys review worker’s compensation settlement agreements. Any agreements that have “full, final, and complete” language (as most or all of them do) will close out any and all subsequent claims for compensation for injuries that relate to the original work accident. An injured party’s attorney may be able to negotiate an exception to the “full, final, and complete” provision for later-discovered injuries, but employers will almost certainly push back against these exceptions.
An injured party’s second option is to do exactly what the employer in this case referred to in its original motion to dismiss the employee’s claim, namely, an employee who determines that he has a claim relating back to an injury after he settles other claims can move to vacate the settlement. A successful motion to vacate can still depend on the language of the settlement agreement and the issues that were contemplated in drafting the settlement. An injured employee who wants to retain this option should consult with an experienced worker’s compensation attorney before he signs any settlement agreements that relate to his injuries.
The attorneys at the Meshbesher Law Firm in Minneapolis have protected the interests of injured employees in worker’s compensation cases for many years. Both employers and employees have great incentives to resolve these cases and to get employees the medical and other treatment they need to get them back to work as soon as is possible. Problems occur when those incentives cause either the employer or the employee to act too quickly, without full and complete consideration of all injuries that can arise both immediately and some amount of time after an accident.
If you have suffered a work-related injury that will be resolved through a worker’s compensation claim, please see our website or contact us if you have any questions or you need representation to optimize the benefits that you will receive in your case.