Schatz v. Interfaith Care Center
2012 Minn. LEXIS 113
| Minn. | 2012Background
- Schatz, a Minnesota employee, injured Jan 26, 2009, while residing in Minnesota; employer and insurer accepted liability.
- She moved to Wyoming for treatment, including two shoulder surgeries in 2009–2010.
- Wyoming providers billed the Minnesota insurer; insurer paid according to Wyoming fee schedule under Minn. Stat. § 176.136, subd. lb(d).
- Schatz sought unpaid balance under Minn. Stat. § 176.135, subd. 1, asserting full liability for medical expenses.
- WJ (WCJ) awarded full payment to Wyoming providers; WCCA reversed, holding § 176.136, lb(d) controlled and limited liability to Wyoming schedule.
- Court of Appeals/relief: Schatz v. Interfaith Care Ctr., 2011 WL 3373690, reversed; Minnesota Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conflict between 176.135(1) and 176.136(lb)(d)? | Schatz: §176.135(1) governs; conflict with §176.136(lb)(d) | Interfaith: no conflict; §176.136(lb)(d) limits out-of-state costs | No irreconcilable conflict; §176.136(lb)(d) limits liability for out-of-state providers |
| Absurd result from applying §176.136(lb)(d)? | Wyoming treatment would yield unfair personal liability | Statute unambiguously implements cost containment, not absurd | statute does not produce absurd result; valid interpretation |
| Jurisdiction of WC Courts to apply out-of-state fee schedules? | Potential expansion of Minnesota Act jurisdiction | Stipulation negates need to interpret Wyoming schedule; issue not presented | Jurisdictionary question not decided due to stipulation; no ruling on out-of-state fee schedule jurisdiction |
| Constitutional challenges to §176.136(lb)(d) as applied (interstate travel, equal protection, due process)? | Strains interstate-travel rights and equal protection; may deprive due process | Statute serves cost containment; no violation | Unreasonable burden not shown; statute constitutional as applied |
Key Cases Cited
- Roraff v. Dept. of Transportation, 288 N.W.2d 15 (Minn. 1980) (limits of §176.135(1) not applicable to out-of-state providers; not controlling here)
- Torres v. California, 435 U.S. 1 (U.S. 1978) (interstate-travel rights and benefits for new residents; not entitlement to previous state benefits)
- Saenz v. Roe, 526 U.S. 489 (U.S. 1999) (right to be treated as a welcome resident under interstate-travel framework)
- Lindell v. Oak Park Coop. Creamery, 369 N.W.2d 505 (Minn. 1985) (workers’ compensation benefits not a vested property right)
- Gluba ex rel. Gluba v. Bitzan & Ohren Masonry, 735 N.W.2d 713 (Minn. 2007) (cost containment legitimate objective; impact on benefits considered)
- Wegener v. Commissioner of Revenue, 505 N.W.2d 612 (Minn. 1993) (rare case exception; evaluating absurd result doctrine)