Minnesota: Costs to Modify Injured Worker’s Residence to Allow For Installation of Lift System Was Limited to Statutory Max of $60K

Installation of a lift system to enable paraplegic to transfer to and from her wheelchair more safely and to live more independently were remodeling costs subject to the $60,000 limit of Minn. Stat. § 176.137, since the system required installation of a ceiling track, which in turn required relocating existing ceiling light fixtures and ceiling fans, installation of blocking in the ceiling along the path of the track, and raising the headers over various doors to be flush with the ceiling, held the Supreme Court of Minnesota recently in Washek v. New Dimensions Home Health, 2013 Minn. LEXIS 189 (Apr. 10, 2013).

The injured worker contended all the expenses qualified as “apparatus” to “cure and relieve from the effects of the injury.” Such provision of reasonably necessary medical treatment had no such $60,000 limit under Minn. Stat. § 176.135. In affirming a split decision of the Workers’ Compensation Court of Appeals, the Supreme Court stressed that the issue was not the cost of the installation of the lift system itself, but rather the cost of the structural modifications necessary to permit the lift system to be installed and used.