Supreme Court Digest: April 24, 2019

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SUPREME COURT

Civil

Workers’ Compensation

Treatment Parameters

This case considered whether the medical treatment parameters established under the workers’ compensation act apply to an employee’s claim for reimbursement of medical expenses that the employer contends are not reasonably necessary. Minn. R. 5221.6020, subp. 2, states that the treatment parameters “do not apply to treatment of an injury after an insurer has denied liability for the injury.”  Relying on this rule, the Workers’ Compensation Court of Appeals concluded that the treatment parameters do not apply when an employer contests its obligation under the workers’ compensation act to pay for an employee’s particular medical treatment.

The Supreme Court held that (1) the treatment parameters established under the workers’ compensation act in Rule 5221.6020, subp. 2, apply to treatment of an injury after liability has been established but do not apply when liability for the compensation benefits owed for an injury has been denied; and (2) an employer that contests its obligation to pay for medical treatment for an employee injury that the employer admits is covered by the workers’ compensation act has not “denied liability for the injury” within the meaning of Rule 5221.6020, subp. 2. Reversed and remanded.

A18-1131 Johnson v. Darchuks Fabrication, Inc. (Workers’ Compensation Court of Appeals)

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Criminal

Sentencing

Conditional Release

Appellant, a participant in the Challenge Incarceration Program administered by the Department of Corrections, contended that he was “released from prison” within the meaning of Minn. Stat. § 169A.276, subd. 1(d), when he entered phase II of that program. Appellant asserted that, under the correct statutory analysis, the state failed to calculate his conditional-release term accurately and revoked his conditional release improperly after it had already ended. The District Court granted judgment on the pleadings to the state on appellant’s ensuing false-imprisonment and negligence claims, and the Court of Appeals affirmed.

The Supreme Court held that (1) the issue of when a felon’s conditional-release term began under Minn. Stat. § 169A.276, subd. 1(d), was sufficiently raised below and was properly before the Court of Appeals; and (2) a felon who participated in the Challenge Incarceration Program, Minn. Stat. §§ 244.17–.173, was “released from prison” for purposes of his conditional-release term under Minn. Stat. § 169A.276, subd. 1(d), when he entered phase II of the Program. Reversed and remanded.

A17-0863 Heilman v. Courtney (Court of Appeals)

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