Oseland v. Crow Wing County
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The Supreme Court affirmed in part and reversed in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming in part and reversing in part the workers' compensation judge's determination that the heirs of relator Richard Island were entitled to interest from Auto-Owners Insurance Group on underpaid disability benefits but that neither penalties nor expenses were warranted, holding that the compensation judge's determinations were supported by substantial evidence.
On appeal, the WCCA affirmed the compensation judge's denial of penalties and expenses but reversed the award of interest from the date of each underpayment of disability benefits, concluding that the heirs were not entitled to interest. The Supreme Court disagreed, holding (1) the underpaid benefits must bear interest from the date of each underpayment, and the interest owed under Minn. Stat. 176.221, subd. 7 accrued at the statutory rate in effect at the time the payment was due; and (2) the compensation judge's determinations regarding penalties and expenses were supported by substantial evidence.
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