In this case, the employee suffered an admitted injury during his employment with Honeywell. This injury occurred in 2010. In August of 2013, the employee entered into a settlement agreement with the insurer for a total of $40,000.00.
Five months after the employee settled his claim with the workers’ compensation insurer, the employee brought an action in Minnesota District Court seeking additional compensation for the injury. The employee alleged that the employer “recklessly” exposed him to chemicals and other hazards during the course of his employment. The employee claimed that the employer had acknowledged that these hazardous materials could cause illness, however, the employer “consciously disregarded” any risks posed by these chemicals. Importantly, the employee did not contend that the employer deliberately intended to cause him injury.
The employer moved to have the employee’s claim dismissed from District Court as the employee did not specifically claim that the employer intended to cause him harm. The judge in the District Court granted the employer’s motion to dismiss stating that the employee had not filed a claim for which he could receive relief.
On appeal, the Court affirmed the decision of the judge. The employee concedes that he did not claim that the employer intentionally meant to cause him harm. The employee argued that because the employer knew that these chemicals could possibly cause harm to the employee that constituted an intent to harm the employee during the course of his work.
The Appeals Court differentiates between an inference of intent and deliberate intent to cause harm. They state “intentionally acting despite the normal risk, with reckless disregard for the possibility that the harm posed by that risk will occur, is not the same as acting with the deliberate intent to cause that harm.” Therefore, the employee could not bring an action in the District Court and it was determined that the proper venue for his claim would be the Workers’ Compensation Court. However, since the Employee settled his workers’ compensation claim, he will be unable to pursue any other recovery in this matter.
In this case, the District Court of Appeals declined to find that an inference of intent on the part of the employer to cause harm cannot be made if the employer willingly places an employee into what could be a dangerous situation. It is not the same as deliberately intending to cause harm to the Employee.