Gillette v. Harold, Inc.
257 Minn. 313, 101 N.W.2d 200, 1960 Minn. LEXIS 533 (1960)
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Rule of Law:
The aggravation of an employee's pre-existing physical infirmity by the ordinary and usual duties of their employment constitutes a compensable 'personal injury' under the Workmen’s Compensation Act, so long as the employment is a proximate contributing cause of the resulting disability.
Facts:
- An employee worked as a saleslady for Harold, Inc., a ladies' ready-to-wear store, for over 17 years.
- Her job required her to be on her feet, standing and walking, for most of her 40-hour work week.
- The employee had a pre-existing, non-work-related deteriorative disorder in the metatarsal phalangeal joint of her left great toe.
- The constant standing and walking required by her employment aggravated this pre-existing condition, causing increased pain and stiffness, particularly at the end of the workday.
- This aggravation progressed to the point of disability, requiring the employee to undergo surgery to alleviate the condition.
- Medical testimony established that if the employee were to only perform household duties and not continue her employment, the surgery would not be necessary.
Procedural Posture:
- The employee filed a claim for workers' compensation benefits with the Minnesota Industrial Commission.
- A referee for the Industrial Commission found the employee's disability was compensable and awarded benefits.
- The employer, Harold, Inc., appealed the referee's decision to the full Industrial Commission.
- The Industrial Commission affirmed the referee's award of compensation.
- The employer and its insurer sought review of the Industrial Commission's order in the Minnesota Supreme Court by writ of certiorari.
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Issue:
Does the aggravation of an employee's pre-existing, non-work-related physical infirmity by the ordinary and usual duties of their employment constitute a compensable 'personal injury' under the Minnesota Workmen’s Compensation Act?
Opinions:
Majority - Murphy, Justice
Yes. The aggravation of a pre-existing infirmity by the ordinary duties of employment constitutes a compensable 'personal injury' when there is a direct causal connection between the employment and the resulting disability. The court reasoned that the 1953 revision to the Minnesota Workmen’s Compensation Act removed the requirement that an injury be 'caused by accident,' broadening the scope of compensable events to include any 'personal injury' arising out of and in the course of employment. This change eliminated the need for an injury to result from a sudden, violent, or unusual event. The court held that injuries may occur gradually from ordinary duties, and the cumulative effect can be as injurious as a single traumatic event. The central question is whether the employment is a proximate contributing cause of the disability. An employer takes an employee as they find them, assuming the risk that the employment might aggravate a pre-existing infirmity, and if such aggravation leads to disability, it is compensable.
Analysis:
This decision significantly broadened the interpretation of 'personal injury' under the Minnesota Workmen’s Compensation Act by decoupling it from the traditional requirement of a sudden 'accident.' The ruling established that a gradual injury, resulting from the cumulative effect of ordinary job duties on a pre-existing condition, is compensable. This shifts the legal focus from the nature of the injurious event to the causal link between the work environment and the resulting disability, making it easier for employees with underlying health issues to receive compensation for work-related aggravations.
