Many states have developed workers compensation systems entitling employees to receive compensation for workplace injuries, regardless of fault, which also allow employers to know what liability they face for such injuries. In keeping with that purpose, Minnesota has been willing to find most injuries that occur in the workplace to be covered under its Workers Compensation Act ("WCA"). Indeed, based upon these principles, the Minnesota Supreme Court recently barred an employee claim for injuries resulting from a "birthday spanking" against an employer and, in the process, reaffirmed Minnesota’s broad definition of injuries covered by the WCA. See Meintsma v. Loram Maintenance of Way, Inc., 684 N.W.2d 434 (Minn. 2004).
In Meintsma, Loram Maintenance of Way’s unionized workforce had a long-standing tradition of spanking fellow union members on their birthdays. The union employees would approach the "birthday boy," wrestle him to the ground, and hit him on the buttocks, sometimes using a long wooden paddle crafted from a two-by-four. The spankings would occur on Loram property during working hours or immediately after them, but not every employee received them. Loram’s managers knew of the spankings, but did nothing to stop them. In fact, a manager even participated in one of the spankings.
Based on this tradition, on a day near his birthday, coemployees grabbed Meintsma, wrestled him to the ground, and spanked him with a wooden paddle. As a result of the incident, Meintsma suffered injuries. Meintsma and an emergency room doctor reported the incident to the police. The employees involved in the incident subsequently pled guilty to criminal charges. Prior to this incident, no one had complained to Loram about being injured as a result of a spanking. The day after the spanking, Meintsma notified Loram of his injuries and Loram filed a first report of injury. While the workers compensation carrier initially accepted liability, it denied coverage upon learning that the individuals involved in the incident had been criminally charged.
Meintsma sued his employer Loram, alleging that he suffered back and psychological injuries, as well as financial damages, as a result of the incident. The case ended up before the Minnesota Supreme Court to address whether the WCA applied to the claims. The Supreme Court rejected Meintsma’s argument that the WCA did not apply because his injury was the result of personal animosity among co-workers and did not involve his employer’s business of railroad maintenance. The Supreme Court found significant that the conduct occurred during working hours and the only meaningful contact with co-employees was in the workplace. The Court also rejected Meintsma’s argument that the WCA did not apply because the conduct he suffered was the result of an intentional injury. Meintsma had no proof that Loram harbored a conscious and deliberate intent to injure him. As such, the WCA provided Meintsma with his exclusive remedy against Loram.
Lessons for Employers
Meintsma indicates that Minnesota employers can often rely upon the WCA when employees institute legal action based upon injuries occurring at work. However, employers should remain vigilant to conduct by employees that can result in injuries to other employees. An additional lesson from the Meintsma case is that employers should be vigilant about completing workers compensation forms when injuries occur at work, no matter how they occur. Meintsma indicates that even in those situations that appear egregious at first blush, the WCA may provide a defense to later litigation.
If you have any questions about Meintsma or other Minnesota legal issues, please contact Judi Williams- Killackey at 414.277.5439 / jkillack@quarles.com or your Quarles & Brady attorney.