Minnesota: Settlement Agreements May Close Out Future Consequential Injuries

Reversing the state’s Workers’ Compensation Court of Appeals, the Supreme Court of Minnesota held that a workers’ compensation settlement agreement may close out not only the injury that was the subject of the agreement, but also conditions and complications arising out of the injury; it is not necessary that the condition or complication be specifically referenced in the settlement agreement. The Court indicated the lower court had, for several decades, misconstrued the high court’s earlier holding in Sweep v. Hanson Silo Co., 391 N.W.2d 817 (Minn. 1986). The Supreme Court acknowledged that under Sweep, a settlement agreement could not close out other distinct, work-related injuries not at issue in the claim petition and, therefore, not in dispute at the time of the agreement. But Sweep did not address whether a settlement agreement may close out conditions or complications that arise from, or are a consequence of, the work-related injury that is the subject of the settlement. The Court said that Minn. Stat. 176.521 allows the parties to settle any claim for compensation, which includes future consequential injuries. The proper procedure for a consequential injury claim after a settlement is to file a petition to vacate.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is the co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance.

See Ryan v. Potlatch Corp., 2016 Minn. LEXIS 424 (July 13, 2016)

See generally Larson’s Workers’ Compensation Law, § 131.04.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law