Gilbertson v. Williams Dingmann, LLC

Summary

The Minnesota Supreme Court considered whether an offer to return to work with the same employer was consistent with a rehabilitation plan identifying a vocational goal of returning to work with a different employer in the same industry. Applying the plain meaning of Minn. Stat. § 176.101, subd. 1(i), the court held that the job offer was inconsistent with the plan because the parties had agreed to a different-employer goal. The court affirmed the Workers’ Compensation Court of Appeals’ decision reversing discontinuance of temporary total disability benefits.

Holdings

1. Under Minn. Stat. § 176.101, subd. 1(i), an offer to return to work with the same employer is not consistent with an employee's rehabilitation plan stating that the vocational goal is to return to work with a different employer.

Questions Presented

1. Whether, under Minn. Stat. § 176.101, subd. 1(i) (2016), an offer to return to work with the same employer is consistent with a rehabilitation plan stating that the employee's vocational goal is to return to work with a different employer in the same industry.
2. Whether the employer could discontinue temporary total disability benefits when the employee refused a job offer that was inconsistent with the filed rehabilitation plan.

Disposition

affirmed