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Harrison v. Cleaning Concepts, Inc.

Citations: 526 N.W.2d 46; 1994 Minn. LEXIS 977; 1994 WL 712915Docket: No. C1-94-910

Court: Supreme Court of Minnesota; December 22, 1994; Minnesota; State Supreme Court

Narrative Opinion Summary

The case involves a dispute over the determination of permanent total disability and the application of the multiple injury formula in the realm of workers' compensation. The employee, injured in 1984 and again in 1990, sought revisions to his permanent total and partial disability status. Initially, the compensation judge ruled the employee was permanently totally disabled as of November 6, 1991. However, the Workers' Compensation Court of Appeals (WCCA) reversed this finding, declaring the disability commenced on October 10, 1990, and reduced the permanent partial disability rating using a multiple injury formula. The employee contested these findings, arguing they were unsupported by the evidence. The higher court ultimately sided with the employee, reinstating the original decision of the compensation judge, recognizing separate impairment ratings for each injury. Additionally, the employee was found eligible for retroactive social security disability benefits, with provisions ensuring compliance with statutory limits on combined benefit amounts. The court also awarded $400 in attorney fees to the employee, underscoring the procedural nuances in applying Minnesota's workers' compensation statutes and related rules.

Legal Issues Addressed

Attorney Fees Award in Workers' Compensation Cases

Application: The court awarded attorney fees to the employee as part of the reinstated compensation judge's findings.

Reasoning: The decision of the WCCA was reversed, reinstating the compensation judge's findings and awarding the employee $400 in attorney fees.

Multiple Injury Formula Application

Application: The WCCA's application of the multiple injury formula, which reduces the permanent partial disability rating, was contested and ultimately reversed, reinstating separate impairment ratings for different injuries.

Reasoning: The employee also disputes the WCCA's application of the multiple injury formula, which combines impairment ratings from multiple injuries to prevent exceeding the total body impairment percentage.

Permanent Total Disability under Workers' Compensation Law

Application: The case examines the determination of the date of permanent total disability, with the court ultimately reinstating the compensation judge's finding that Harrison was permanently totally disabled as of November 6, 1991.

Reasoning: The compensation judge determined the employee to be permanently totally disabled as of November 6, 1991.

Social Security Disability Benefits and Workers' Compensation

Application: The judgment addressed the interaction between social security disability benefits and workers' compensation, ensuring that combined benefits do not exceed 80% of average current earnings.

Reasoning: Social security disability benefits are adjusted when combined with workers' compensation to not exceed 80% of average current earnings.