Arrowhead Senior Living Community v. Kainz

Summary

The Minnesota Supreme Court reversed a Workers’ Compensation Court of Appeals decision awarding benefits to Carol Kainz for an ankle injury sustained on a workplace staircase. The court concluded that the WCCA’s findings regarding the staircase handrails were manifestly contrary to the evidence and remanded the matter to the compensation judge for reconsideration under the increased-risk test described in Dykhoff v. Xcel Energy.

Holdings

1. The WCCA’s decision was manifestly contrary to the evidence because it relied on internally contradictory findings regarding the location of the handrails and failed to account for photographic evidence showing that the handrails extended all the way down the staircase.
2. The case must be remanded to the compensation judge to reconsider the compensability of Kainz’s injury in light of Dykhoff and the unresolved evidence concerning whether the staircase presented a special hazard.

Questions Presented

1. Whether the WCCA’s determination that Kainz’s injury arose out of her employment under the increased-risk test was manifestly contrary to the evidence.
2. Whether the matter should be remanded to the compensation judge for reconsideration under the increased-risk test established in Dykhoff.

Disposition

reversed_and_remanded