Martin v. Morrison Trucking, Inc.
803 N.W.2d 365
Minn.2011Background
- Martin, a Minnesota resident, injured his ankle while working for Morrison Trucking, Inc. in Minnesota on July 31, 2002.
- Morrison Trucking, Wisconsin-based, carried Wisconsin workers’ compensation insurance via Travelers through the Wisconsin Pool.
- Travelers denied Minnesota benefits, citing an exclusion for Minnesota coverage in Morrison’s policy.
- SCS settled Martin’s Minnesota claim and sought reimbursement from Morrison; Travelers was joined by Morrison in the action.
- The compensation judge found Morrison uninsured for Minnesota liability and ordered reimbursement plus a 65% penalty under Minn. Stat. § 176.183, subd. 2.
- WCCA reversed the judge, declaring the Minnesota exclusion invalid under Wisconsin law, and then the Supreme Court reversed that outcome on jurisdictional grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WCCA had jurisdiction to invalidate an unambiguous insurance exclusion based on Wisconsin law. | Morrison Trucking argued Travelers’ Minnesota exclusion should be upheld; WCCA should assess Minnesota Act only. | SCS/WCCA claimed Wisconsin policy exclusion violated Wisconsin Pool rules and Minnesota Act principles allowing invalidation. | WCCA lacked authority to declare an unambiguous contract term invalid based on another state's law. |
| Whether the Minnesota compensation order could be sustained given the policy exclusion and jurisdictional limits. | Judge’s findings of non-insurance were proper under Minnesota Act provisions for uninsured employers. | WCCA erred in applying Wisconsin-Pool policy interpretation to Minnesota liability. | Judge’s findings and order reinstated; reversal of WCCA. |
Key Cases Cited
- Hale v. Viking Trucking Co., 654 N.W.2d 119 (Minn. 2002) (limits WCCA subject-matter jurisdiction across state-law questions)
- Rundberg v. Hirschbach Motor Lines, 51 Minn. Workers’ Comp. Dec. 193 (Minn. WCCA 1994) (WCCA lacks jurisdiction to apply Nebraska law to Minnesota employee claim)
- Freeman v. Armour Food Co., 380 N.W.2d 816 (Minn. 1986) (WCCA can order reimbursement where statute authorizes, not determine unrelated liability)
- Botler v. Wagner Greenhouses, 754 N.W.2d 666 (Minn. 2008) (limits of Minnesota Act authority to guardian costs vs. liability)
- Seehus v. Bor-Son Constr., Inc., 783 N.W.2d 144 (Minn. 2010) (WCCA/compensation court jurisdiction tied to Minnesota Act interpretation)
- Wiss v. Advance United Expressway, 488 N.W.2d 802 (Minn. 1992) (MIGA Act vs. Minnesota Act jurisdictional distinctions)
- Taft v. Advance United Expressways, 464 N.W.2d 725 (Minn. 1991) (jurisdictional boundaries between Minnesota Act and MIGA Act)