The employee was brutally stabbed by a personal acquaintance who entered the employee’s workplace. It was determined the acquaintance believed the employee had killed his uncle. It was established the employee’s uncle had died of a heart condition without any suspicious circumstances. The acquaintance was criminally charged, but determined to be mentally incompetent to stand trial.
Primary liability was denied on the basis that the attack was for personal reasons and not a dispute that arose out of the employee’s employment. Under Minnesota law, injuries caused by a third person due to personal reasons, and not directed against the employee due to the employment are not compensable. In this case, the employee’s theory of liability was that due to the acquaintance’s mental incapacity, he was unable to “intend to injure” the employee for personal reasons. A workers’ compensation judge denied the employee’s claims. The Workers’ Compensation Court of Appeals affirmed. The Minnesota Supreme Court affirmed the WCCA, holding that regardless of the acquaintance’s mental state, his motivation was solely personal and unrelated to the employee’s work activities.
Going Forward
It is important to investigate the motive behind an attack to determine whether it was due to personal issues between the parties or a dispute that arose out of the work environment.