The Minnesota Supreme Court affirmed workers' compensation benefits for Erin Lindsay, a Minneapolis Public School District middle school teacher who injured her knee while playing basketball with students during afterschool practice. The decision, filed Oct. 22, 2025, clarifies the scope of workers' compensation coverage for injuries occurring during employment-related activities at the workplace.
Lindsay sustained the injury while participating in an afterschool basketball practice with her students. When she sought workers' compensation benefits, the self-insured school district denied liability, arguing the injury occurred during a voluntary recreational activity excluded from coverage under state law.
The case centered on two key legal issues: whether Lindsay's injury occurred 'in the course of employment' under Minnesota Statutes section 176.021, subdivision 1, and whether the recreational activity exclusion under subdivision 9 applied to bar her claim.
Justice Gaïtas, writing for the court, held that Lindsay's injury clearly occurred 'in the course of employment' based on three undisputed facts. First, the injury happened within an hour of the end of the regular workday. Second, it occurred at the workplace. Third, Lindsay was engaged in employment-related activity when injured.
The court emphasized that afterschool activities involving students constitute employment-related duties for teachers, even when they involve recreational elements like sports. The timing and location of the injury, combined with Lindsay's supervisory role with students, brought the incident within the scope of her employment responsibilities.
Regarding the recreational activity exclusion, the court provided important clarification of Minnesota Statutes section 176.021, subdivision 9. This provision excludes from workers' compensation liability injuries that occur while an employee participates in a voluntary employer-sponsored recreational program. However, the court held this exclusion applies only to programs that are primarily for the benefit of employees themselves.
The school district argued that the basketball practice constituted a voluntary recreational program that would exclude Lindsay's injury from coverage. The court rejected this argument, finding that afterschool student activities serve educational and supervisory purposes rather than employee recreation. The primary beneficiaries of such programs are students, not staff members who participate in their professional capacity as educators and supervisors.
This distinction is crucial for educational institutions and their employees. The ruling establishes that when teachers engage in afterschool activities as part of their professional duties—such as coaching, supervising, or participating in student programs—any resulting injuries remain covered by workers' compensation even if the activities have recreational components.
The case proceeded through the workers' compensation administrative process before reaching the state's highest court. Following an administrative hearing, a compensation judge initially determined that Lindsay's claim was compensable. The Workers' Compensation Court of Appeals upheld this decision, prompting the school district to seek review from the Minnesota Supreme Court.
Lindsay was represented by attorneys Jeremiah W. Sisk and David B. Kempston of Mottaz & Sisk Injury Law. The school district was represented by Joshua M. Steinbrecher and Chris Wehr of Heacox, Hartman, Koshmrl, Cosgriff, Johnson, Lane & Feenstra.
The decision has significant implications for educational institutions statewide. School districts must recognize that teachers and staff participating in afterschool activities as part of their employment duties remain covered by workers' compensation insurance. This includes coaching, supervising student events, and participating in educational programs that extend beyond regular school hours.
For workers' compensation law, the ruling reinforces the broad interpretation of 'course of employment' when activities occur at the workplace, during or shortly after work hours, and involve employment-related duties. The court's analysis of the recreational activity exclusion also provides important guidance for determining when such exclusions apply.
The timing element—injury occurring within an hour of the workday's end—suggests courts will consider reasonable extensions of the work period when evaluating coverage. This is particularly relevant for professions like teaching where duties often extend beyond traditional hours through extracurricular activities and student supervision.
Educational institutions should review their workers' compensation policies and ensure adequate coverage for staff participating in afterschool and extracurricular activities. The decision clarifies that such activities, when performed as part of employment duties, do not fall outside workers' compensation protection simply because they involve recreational elements.
The Minnesota Supreme Court's affirmation provides certainty for educators who participate in student activities as part of their professional responsibilities. Teachers can be assured that injuries sustained while fulfilling these expanded duties remain covered by workers' compensation insurance, even when the activities involve sports or other recreational components that primarily benefit students rather than staff.