Roller-Dick v. CentraCare Health SystemAnnotate this Case
The Supreme Court affirmed the decision of the Workers’ Compensation Court of Appeals (WCCA) that Plaintiff’s injury “arose out of” her employment under the “increased-risk” test the Court applied in Dykhoff v. Xcel Energy, 840 N.W.2d 821 (Minn. 2013).
Plaintiff, an employee of Relator, fell down a set of stairs as she was leaving work. The workers’ compensation judge held that the injury did not arise out of employment. The WCCA reversed, determining that the compensation judge applied the incorrect test to determine whether the stairs were hazardous and that the correct test was whether the stairs posed an “increased risk” as opposed to a “neutral risk.” Because the stairs alone increased Plaintiff’s risk of injury, the WCCA concluded that her injury arose out of her employment. The Supreme Court affirmed, holding (1) an injury arises out of employment when there is a causal connection between the injury and the employment; and (2) applying that rule, there was a causal connection between Plaintiff’s injury on the stairway and her employment.