High court grants comp benefits to teacher injury at basketball practice

A Minnesota law shielding employers from liability for injuries suffered during voluntary recreational programs applies only to programs that benefit employees, the state’s Supreme Court held Wednesday, ruling that a high school math teacher injured while playing basketball with students was injured in the scope of her employment.

“We conclude that a voluntary employer-sponsored recreational program under Section 176.021, subdivision 9, is a program for the benefit of employees,” the high court said in Workers’ Compensation Court of Appeals (Erin Lindsay) v. Minneapolis Public School District.

Erin Lindsay was working as a math teacher at Sullivan STEAM School, a magnet school focusing on science, technology, engineering, arts and math. Teachers were expected to participate in activities intended to build stronger relationships with students and their families.

In February 2023, Ms. Lindsay, who testified she often sought to connect with students by participating in activities on campus, asked the basketball coach for permission to join practice. She ruptured the anterior cruciate ligament in her left knee during a rebounding drill.

The injury required surgery and physical therapy, and Ms. Lindsay missed more than a month of work.

She filed a workers compensation claim, which the self-insured Minneapolis Public School District denied, arguing that Minnesota Statutes Section 176.021(9) precludes coverage for injuries sustained during voluntary employer-sponsored recreational programs.

A workers compensation judge determined Lindsay was entitled to benefits, finding that the injury occurred within a reasonable time after working hours and that she was at the practice because the school encouraged teachers to build relationships with students.

The judge also held the statutory exclusion for voluntary recreational activities applies only to programs intended to benefit employees, and because Ms. Lindsay was not participating in practice for her personal benefit, the injury was compensable.

The Workers’ Compensation Court of Appeals affirmed, as did the state’s highest court, stating that the case marked the first time the court addressed the entire phrase “voluntary recreational programs sponsored by the employer.”

The high court said there is only one reasonable interpretation of the statute: it precludes coverage only for injuries suffered during programs intended to benefit the employees.

The court said the ordinary meaning “recreation” and “recreational programs” can only reasonably refer to programs that are for the benefit of employees, and examples listed in the statute — athletic events, parties and picnics — are employer-sponsored events for employee enjoyment.

The court also said the headnote for Section 176.021(9) is “Employer responsibility for wellness programs,” further shows the statute refers to programs that benefit employees because the word “wellness” connotes activities that support personal well-being.

“Finally, we are convinced that the Legislature’s use of the word ‘voluntary’ indicates that voluntary employer-sponsored recreational programs are programs that benefit employees,” the Supreme Court said.

Applying this interpretation, the court rejected the school district’s argument that the student basketball practice at Sullivan was a voluntary employer-sponsored recreational program within the meaning of the statute.

Finding the injury was not precluded by law, the court then turned to whether it arose out of employment.

The court said an injury occurs within the course of employment if it happens during work hours or within a reasonable period after working hours, if the employee is engaged in activities incidental to employment.

Ms. Lindsay typically worked until 3 p.m. or 3:30 p.m.; she was injured around 4 p.m. The high court said it previously found injuries occurring up to an hour outside work hours fall within a reasonable period, and therefore, her injury did as well.

It also held that her participation was incidental to her employment. The undisputed facts showed she joined practice at her student’s request, consistent with the school’s encouragement and her employment contract.

While the school district argued that participating in basketball practice wasn’t remotely related to teaching math, the high court said that view was too narrow.

“Lindsay participated in the basketball practice to strengthen her relationships with students,” the court said. “Under Sullivan’s approach to teaching, strengthening relationships with students was part of Lindsay’s work as a teacher.”

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