Keith Daniel v. City of Minneapolis

Summary

The court held that an employee may pursue Minnesota Human Rights Act claims for disability discrimination even when the underlying disability resulted from a work-related injury compensated under the Minnesota Workers’ Compensation Act. The court reasoned that the statutes address distinct injuries and provide different remedies, so the workers’ compensation exclusivity provision does not bar discrimination claims arising from an employer’s later failure to accommodate or retaliation. The court overruled its contrary precedent, reversed the court of appeals, and remanded for further proceedings. Justice Anderson, joined by Chief Justice Gildea, dissented, concluding that the discrimination claim was nevertheless “on account of” the compensated workplace injury and therefore barred by workers’ compensation exclusivity.