MINNEAPOLIS (Legal Newsline) – A Minnesota Supreme Court majority ruled Aug. 8 that a woman’s workplace injury satisfied the “requisite causal connection between the workplace and her injury.”
The question of whether or not plaintiff Laurie A. Roller-Dick’s injuries “arose out of” her employment was contested by the Workers' Compensation judge, who maintained that the plaintiff’s injuries did not arise out of employment because Roller-Dick failed to establish that the stairs were more hazardous than stairs she might encounter in everyday life or that her work duties in some way increased her risk of falling as she descended them, the ruling stated.
Justice Anne K. McKeig wrote the majority opinion.
Roller-Dick fell down the stairs of her place of employment, relator CentraCare Health System, fracturing her ankle. At the time, she was holding a plant from her desk and her hand bag was “hanging from the crook of her elbow,” the ruling states. Because she was holding the plant, she was unable to grab the available handrail, the ruling states.
The compensation judge stated that because Roller-Dick was not able to identify a work-related reason why she was not using the handrails, her claim was rejected.
The Workers’ Compensation Court of Appeals (WCCA) disagreed and asserted that the compensation judge had “applied the incorrect legal test,” the Supreme Court said. The correct test, according to the WCCA, was “whether the stairs posed an ‘increased’ risk as opposed to a ‘neutral’ risk,” the ruling states.
The Supreme Court’s majority agreed with the WCCA. They stated that the circumstances of that day, which included Roller-Dick holding a plant, “created an increased risk that Roller-Dick would fall and injure herself on the stairs, thus satisfying the requisite causal connection between the workplace and her injury.”
Chief Justice Lorie Skjerven Gildea dissented and maintained that Roller-Dick “did not establish a causal connection,” stating that “something more needs to be shown” to prove the ‘arising out of’ element" of the injury.
“When the stairway complies with all relevant safety standards, there is simply no room for the conclusion that the stairway is a hazard,” Gildea wrote.
Minnesota Supreme Court case number A17-1816