Court Ponders Without Deciding Whether Firefighter Entitled To Insurance Benefits As Result Of Chair Injury

Scott Sletten was employed as a firefighter for the City of St. Paul, Minnesota from 1992 to 2006. In 2002, Sletten injured his left shoulder and ruptured a disk in his neck. The injury occurred when Sletten picked up a chair to carry it into the kitchen at the fire station. Sletten applied for and received workers’ compensation benefits as a result of the injury.

After he returned to work, Sletten reinjured himself in 2004 while performing a cave rescue. Over time, Sletten’s condition worsened.

In 2006, Sletten was awarded a Public Employees Retirement Association duty-related disability pension. Shortly afterwards, he applied for health insurance benefits under a Minnesota statute that requires employers to pay health insurance until a firefighter reaches the age of 65 if the “firefighter suffers a disabling injury that: (1) Results in the firefighter’s retirement or separation from service; (2) occurs while the firefighter is acting in the course and scope of his duties as a firefighter; and (3) the firefighter has been approved to receive the firefighter’s duty-related disability pension.”

When the City denied Sletten’s application, he challenged the denial in the Minnesota Court of Appeals. The Court upheld Sletten’s request for health insurance benefits.

The Court discussed at some length whether, under the Minnesota statute, there need be anything particular to firefighting (or law enforcement) related to the injury in order to qualify the injury for health insurance benefits. In the end, the Court concluded that prior cases “articulate that there is no narrow limiting requirement that the injury be indigenous to fighting fires or police work. In other words, an applicant for benefits does not have to sustain an injury while ‘fighting fires’ or ‘shooting at the bad guys’ in order to be eligible for benefits.”

The Court waxed on a bit about whether Sletten would be entitled to benefits for the injury he suffered moving his chair: “Anybody can end up moving a piece of office furniture around, assuming it was something they should be doing as part of the workday. Any secretary, housewife, gardener, plumber, doctor, lawyer, judge, cleaning his or her office, any of those groups could move a chair or table, suffer an arm, leg, or back injury, and pull workers’ compensation. On the other hand, the injuries received during work hours and on a task either explicitly or implicitly assigned to you and if you put a claim for workers’ compensation benefits and it is honored, Sletten argues why should the inquiry go any further.”

In the end, the Court decided that it was not required to “answer the precise question of ‘the chair.’” Since Sletten suffered an injury in the cave rescue, and since engaging in a cave rescue was clearly a firefighter function, Sletten was entitled to health care benefits.

In re Claim for Benefits by Scott Sletten, 2007 WL 4472476 (Minn.App. 2007).

This article appears in the March 2008 issue