Block v. Exterior Remodelers, Inc., A19-0584 - a podcast by TCL Media

In 1992, relator Galen T. Block settled a claim for a work-related injury. Twenty-four years later, in 2016, the Workers’ Compensation Court of Appeals (WCCA) granted Block’s petition to vacate the 1992 settlement. The WCCA concluded that there was no mutual mistake of fact that required vacating the settlement, but the substantial change in Block’s condition warranted doing so. Respondents Exterior Remodelers, Inc. and RTW Group claimed that they were entitled to a credit for the previously paid settlement, arguing that Minn. Stat. § 176.179 (1988), did not apply to payments that were not made under a mistake of fact or law. The compensation judge concluded that respondents were entitled to a 100 percent credit for the previously paid settlement, and the WCCA affirmed.

On appeal to the supreme court, the following issues are presented: (1) whether Minn. Stat. § 176.179 applies to payments made by insurers pursuant to stipulations that are later vacated, (2) whether the payment in this case is “mistaken compensation” as that term is used in Minn. Stat. § 176.179, and (3) whether the compensation judge erred by awarding a 100 percent credit for the previously paid settlement. (Workers Compensation Court of Appeals).

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