Noga v. Minn. Vikings Football Club

Summary

The Minnesota Supreme Court considered whether former Minnesota Vikings player Alapati Noga's workers' compensation claim for dementia caused by repetitive head trauma was timely under Minn. Stat. § 176.151. The court held that the statute of limitations barred the claim because the Vikings' provision of over-the-counter medication and related care did not constitute a qualifying proceeding indicating acceptance of liability for the later-diagnosed Gillette injury. Because the limitations issue was dispositive, the court did not decide whether Noga sustained a compensable injury or received adequate notice.

Holdings

1. An employer's provision of care does not constitute a proceeding under Minn. Stat. § 176.151 unless it arises from the employer's awareness of an obligation for the benefits provided, reflecting an acceptance of responsibility for the work-related injury at issue. The Vikings' provision of Advil and Tylenol and related care for Noga's headaches and wooziness did not constitute a proceeding that satisfied the statute of limitations for his later-diagnosed dementia claim.

Questions Presented

1. Whether the Vikings' provision of care for Noga's headaches and wooziness constituted a proceeding under Minn. Stat. § 176.151 that satisfied or tolled the statute of limitations for his later-diagnosed Gillette dementia injury.

Disposition

reversed_and_remanded