As to the latter statutory argument, Profit relies on Meils ex rel. Meils v. Northwestern Bell Telephone Co. , a decision dealing with an employee's suicide. 355 N.W.2d 710 (Minn. 1984).
v. Fox, 401 A.2d 97, 100 (Del. Super. 1979), aff'd, 411 A.2d 606 (Del. 1980) ; Meils by Meils v. Northwestern Bell Telephone Co., 355 N.W.2d 710, 715 (Minn. 1984) ; Campbell v. Young Motor Co., 211 Mont. 68, 684 P.2d 1101, 1103 (1984) ; Vredenburg v. Sedgwick CMS, 124 Nev. 553, 188 P.3d 1084, 1090 (2008) ; Borbely v. Prestole Everlock, Inc., 57 Ohio St.3d 67, 565 N.E.2d 575, 578 (1991) ; Matter of Death of Stroer, 672 P.2d 1158, 1161 (Okl. 1983) ; see also Kealoha v. Director, Office of Workers, 713 F.3d 521, 524-25 (9th Cir. 2013). The chain-of-causation test addresses the requisite causal connection between the prior work-related injury and the employee's subsequent death by suicide to permit an award of workers’ compensation death benefits, even where there are statutory limitations on injuries caused by an employee's willful act, as we have here in New Hampshire.
Did the employer's workers' compensation insurer properly discontinue payment of dependency compensation for the benefit of the deceased employee's minor children following the remarriage of their mother, his surviving spouse, on June 11, 1983? Although the Workers' Compensation Court of Appeals (WCCA) affirmed the determination of the compensation judge that the discontinuance was authorized by Minn.Stat. § 176.111, subd. 21 (1982), we have concluded that the children remained entitled to benefits pursuant to the construction we gave section 176.111, subds. 21 and 10, in Meils, by Meils v. Northwestern Bell Telephone Co., 355 N.W.2d 710 (Minn. 1984). The underlying facts are not in dispute.
But, this hole may also be a deliberate legislative choice. See, e.g., Meils ex rel. Meils v. Nw. Bell Tel. Co. , 355 N.W.2d 710, 713 (Minn. 1984) (explaining that "workers’ compensation is solely a creature of statute" and "policy decisions regarding the scope of [the statutory remedy] are properly for the legislature"). Regardless, Smithfield’s hole is for the Legislature to fill or not fill as it chooses.
Minn. Stat. § 176.021, subd. 1 (1998). Thereafter, in Meils by Meils v. Northwestern Bell Telephone Co., 355 N.W.2d 710 (Minn. 1984), we held to be compensable a suicide death that resulted from depression precipitated by a work-related back injury. In so doing we rejected the Anderson "uncontrollable impulse or delirium of frenzy" test for causation, replacing the causal test with "the familiar common law test of proximate cause and superseding cause."
However, it is clear from a review of the entire record, including plaintiff's deposition testimony, his affidavit, and the report of his treating psychologist, that plaintiff has not suffered physical injury. Defendant cites Meils v. Northwestern Bell Co., 355 N.W.2d 710 (Minn. 1984), for the proposition that the aggravation of mental injuries "may" be compensable by the WCA. Def. Reply Brief at 10 n. 13.
The law in Minnesota strikes a delicate balance between societal and individual interests when dealing with the rights and responsibilities of the mentally ill. See Minn. Const. art. VII, § 1 (insane or mentally incompetent persons ineligible to vote); Minn. Stat. § 595.02(f) (1990) (person of unsound mind incompetent to testify); Minn. Stat. § 611.026 (1990) (excusing criminal liability where the actor, because of mental illness, did not know the nature of the act or that it was wrong); see also Meils v. Northwestern Bell Telephone Co., 355 N.W.2d 710, 714 (Minn. 1984) (suicide compensable under Workers' Compensation Act where injury causes mental derangement of such severity that it overrides normal, rational thinking and judgment); Anderson v. Armour Co., 257 Minn. 281, 101 N.W.2d 435 (1960); Olsson v. Midland Ins. Co., 138 Minn. 424, 430, 165 N.W. 474, 476 (1917) (allowing recovery under accidental death policy where the insured's suicide was a product of insured's insanity).Wicka, 474 N.W.2d at 330-31.
The law in Minnesota strikes a delicate balance between societal and individual interests when dealing with the rights and responsibilities of the mentally ill. See Minn. Const. art. VII, § 1 (insane or mentally incompetent persons ineligible to vote); Minn. Stat. § 595.02(f) (1990) (person of unsound mind incompetent to testify); Minn. Stat. § 611.026 (1990) (excusing criminal liability where the actor, because of mental illness, did not know the nature of the act or that it was wrong); see also Meils v. Northwestern Bell Telephone Co., 355 N.W.2d 710, 714 (Minn. 1984) (suicide compensable under Workers' Compensation Act where injury causes mental derangement of such severity that it overrides normal, rational thinking and judgment); Anderson v. Armour Co., 257 Minn. 281, 101 N.W.2d 435 (1960); Olsson v. Midland Ins. Co., 138 Minn. 424, 430, 165 N.W. 474, 476 (1917) (allowing recovery under accidental death policy where the insured's suicide was a product of insured's insanity). Wicka, 474 N.W.2d at 330-31.
We have also used a three-part formulation of rational basis review, which requires that (1) the distinction between the classes be "genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs"; (2) there be "an evident connection between the distinctive needs peculiar to the class and the prescribed remedy"; and (3) "the purpose of the statute be one that the state can legitimately attempt to achieve." Miller Brewing Co. , 284 N.W.2d at 356 (citing Schwartz v. Talmo , 295 Minn. 356, 205 N.W.2d 318, 323 (1973), superseded by statute as stated inMeils ex rel. Meils v. Nw. Bell Tel. Co. , 355 N.W.2d 710, 714 (Minn. 1984) ; Montgomery Ward & Co., Inc. v. Comm'r of Taxation , 216 Minn. 307, 12 N.W.2d 625 (1943) ). We have applied yet another formulation of the very same constitutional equal protection principle in some workers’ compensation cases.
The remedy provided by the workers' compensation act is "solely a creature of statute" based on "policy decisions" that "are properly for the legislature." Meils ex rel. Meils v. Nw. Bell Tel. Co. , 355 N.W.2d 710, 713 (Minn. 1984) (emphasis added). "[T]he rule of exclusiveness of remedy may seem harsh, but the remedy therefor is wholly legislative."