In Schmitz v. U.S. Steel Corp., a divided Minnesota Supreme Court held that the state constitutional right to a jury trial applied to individuals bringing suit under the retaliatory discharge provision of the Workers’ Compensation Act (WCA). The court determined, as a matter of law, that the nature of the controversy overrode the default presumption that matters arising under the WCA are not entitled to jury trials.
This case note first provides an abbreviated history of the civil right to a jury trial, the WCA, and the evolving claim of retaliatory discharge. It then fuses these histories and discusses jury trials in cases where an employee is discharged in retaliation for exercising his or her workers’ compensation rights.
This note then turns to the Schmitz decision, recounting both the majority and dissenting opinions. Although this note finds the court ultimately came to the correct conclusion, it contends that the court erred by finding that section 176.82 of the WCA was unambiguous. It explores an additional avenue of analysis—statutory interpretation—which further supports the Schmitz holding. The court ought to have compensated for ambiguities within the WCA, whether by applying textual canons of construction or employing the purposive approach.