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An injured worker who entered into a settlement agreement with her employer cannot pursue an additional claim for consequential depression and anxiety, the Minnesota Supreme Court has ruled.
Virgenia M. Ryan injured her back moving heavy paper products while working at a Potlatch Corp. manufacturing facility in Bimidji, Minnesota, court records show.
Ms. Ryan underwent back surgery in 2002, which did not completely resolve her pain, according to records. In 2003, she and Spokane, Washington-based Potlatch entered into a settlement agreement that excluded future reasonable and necessary medical treatment.
After going back to school and then working as a medical secretary for several years, Ms. Ryan's lower back pain worsened, records show. After undergoing additional surgeries, a psychiatrist who evaluated her in the hospital found that she suffered from depression related to her back injury.
Ms. Ryan was diagnosed with “major depressive disorder” in November 2009 and continued treatments through January 2013 when she sought additional benefits for her 2002 injury, according to records. Potlatch argued that it already paid benefits for the injury and that the claim was “fully and finally resolved” by the settlement agreement.
The company moved to dismiss the petition, saying Ms. Ryan would be required to vacate the existing settlement agreement before she could bring a new claim, records show. But a workers comp judge denied Potlatch's motion, saying the 2003 settlement didn't bar a claim for chronic pain and related depression. The Minnesota Workers' Compensation Court of Appeals affirmed the judge's decision, leading Potlatch to appeal.
The Minnesota Supreme Court on Wednesday unanimously reversed and remanded the case to the appeals court, ruling that a workers comp settlement agreement may close out the occupational injury as well as “conditions and complications arising out of the workers compensation injury.”
While Ms. Ryan argued that her depression is a new condition that was not raised during at the time of the settlement agreement, the state Supreme Court said it's a psychological condition arising out of her workers comp injury and, therefore, falls within the scope of the settlement agreement.
In addition, the ruling states that the condition or complication doesn't need to be “specifically referenced in the settlement agreement.” As a result, Ms. Ryan must petition to vacate the 2003 settlement before proceeding with an additional claim for benefits.
An Idaho man who failed to prove his occupational injuries were the “predominant” cause of his depression is not entitled to benefits for psychological care, the state Supreme Court has ruled.