In Virgenia M. Ryan v. Potlatch Corporation and Self-Insured/Comp Cost, Inc., — N.W.2d — (Minn. July 13, 2016), Virgenia M. Ryan sustained a back injury arising out of and in the course of her employment, and agreed to a “full, final, and complete settlement.” Years later, she filed a claim petition alleging her back injury caused depression and anxiety. Her employer, Potlatch Corporation, moved to dismiss the petition. A compensation judge denied the motion. The WCCA affirmed. The Supreme Court, however, reversed and remanded the case to the trial court, concluding Ryan must petition to vacate the settlement agreement before proceeding with her claim. Read more here.
Supreme Court rules workers’ compensation settlement may close out not only the workers’ compensation injury, but also conditions and complications arising out of the injury, even if the settlement does not specifically reference the condition or complication.