STATE OF MINNESOTA
IN SUPREME COURT
A25-0193
Workers’ Compensation Court of Appeals Gaïtas, J.
Erin Lindsay,
Respondent,
vs. Filed: October 22, 2025 Office of Appellate Courts Minneapolis Public School District (SSD1), Self-Insured,
Relator.
________________________
Jeremiah W. Sisk, David B. Kempston, Mottaz & Sisk Injury Law, Coon Rapids, Minnesota, for respondent.
Joshua M. Steinbrecher, Chris Wehr, Heacox, Hartman, Koshmrl, Cosgriff, Johnson, Lane & Feenstra, P.A., Edina, Minnesota, for relator.
SYLLABUS
1. The employee’s injury occurred “in the course of” employment for the
purpose of Minnesota Statutes section 176.021, subdivision 1 (2024), because the
undisputed facts show that the employee sustained the injury within an hour of the end of
the workday, the injury occurred at the workplace, and the employee was engaged in
employment-related activity.
1 2. Minnesota Statutes section 176.021, subdivision 9 (2024), which excludes
from workers’ compensation liability injuries that occur while an employee is participating
in a voluntary employer-sponsored recreational program, applies only to employer
programs that are for the benefit of employees.
Affirmed.
OPINION
GAÏTAS, Justice.
The employee, a middle school teacher at a Minneapolis public school, injured her
knee while playing basketball with students during an afterschool basketball practice. She
sought workers’ compensation benefits, but the self-insured employer denied liability. The
employee filed a claim petition seeking benefits. Following an administrative hearing on
her claim petition, a compensation judge determined that the employee’s claim was
compensable, concluding that the injury arose out of and in the course of the employee’s
employment and that the exclusion under Minnesota Statutes section 176.021,
subdivision 9 (2024), for “[i]njuries incurred while participating in voluntary recreational
programs sponsored by the employer,” did not apply. The employer appealed to the
Workers’ Compensation Court of Appeals (WCCA), arguing that the employee’s injury
did not occur “in the course of” employment and that section 176.021, subdivision 9,
excluded compensation benefits because the injury occurred during a voluntary
employer-sponsored recreational program. The WCCA affirmed. Because we conclude
that the employee’s injury occurred in the course of her employment and that the exclusion
2 under section 176.021, subdivision 9 applies only to voluntary employer-sponsored
recreational programs that benefit employees, we affirm.
FACTS
Respondent Erin Lindsay has been a math teacher in the Minneapolis Public School
District since 2011 and has worked at Sullivan STEAM School (Sullivan) since 2020. 1 In
February 2023, while playing basketball with her students during an afterschool basketball
practice, Lindsay ruptured the anterior cruciate ligament (ACL) in her left knee. The injury
required surgery and physical therapy, and Lindsay missed more than one month of work.
Lindsay sought workers’ compensation benefits from her employer, relator Minneapolis
Public School District, Special School District 1 (the school district), which was
self-insured for workers’ compensation liability. The school district denied liability.
Lindsay filed a claim petition seeking workers’ compensation benefits. Following an
administrative hearing on her claim petition, a workers’ compensation judge determined
that Lindsay was entitled to benefits. The WCCA affirmed. In this appeal, the school
district challenges the WCCA’s decision.
The undisputed facts in the record before us are as follows. Sullivan is a
preschool-through-eighth-grade magnet school that focuses on science, technology,
engineering, arts, and math (STEAM). It uses a project-based learning model, integrating
21st century skills and social emotional learning into its classes. According to Sullivan’s
principal, the “cultivation of strong relationships and collaboration with students is at the
1 Lindsay did not work for the Minneapolis Public School District between 2017 and 2019.
3 core” of the school’s approach. The principal testified before the compensation judge that
“[i]t’s an expectation at Sullivan that teachers put in [social emotional learning] work and
build relationships with students because [it] yields stronger academic outcomes.”
Sullivan’s mission statement reflects this emphasis on relationship building:
At Sullivan STEAM Magnet, every child has a place and voice. Every member of the learning community creates knowledge and applies practice[s] of STEAM to solve relevant problems with project-based learning in culturally sustained ways[.] . . . [T]his is possible through cultivation of strong relationships in collaboration [with] students, staff, families, and the greater community.
An instructional specialist/reading interventionist at Sullivan testified that the
Standards of Effective Instruction, which Sullivan uses to evaluate teachers, include an
expectation that teachers develop relationships with students and families. According to
the instructional specialist, if a teacher fails to build relationships with students, this
shortcoming will be reflected in the teacher’s formal evaluation, and the teacher will
receive coaching “on how to build better relationships with their students.” The
instructional specialist testified that one method of relationship building is using an “entry
point,” such as an activity of interest to students.
Sullivan teachers have discretion as to how to build relationships with students.
According to Sullivan’s principal, she and Sullivan’s entire administration “encourage . . .
teachers to be as creative as possible” when fostering student-teacher connections. For
example, the principal testified, teachers may participate in student “activities outside of
normal school hours.”
4 Lindsay testified before the compensation judge that she fosters connection with her
students in part by joining them at lunch and recess and attending extracurricular activities,
including sporting events, clubs, music programs, plays, family nights, and teen nights.
The principal testified that she viewed Lindsay’s participation in student activities as part
of Lindsay’s role as a teacher at Sullivan.
When Lindsay was injured, the workday for Sullivan teachers officially began at
7:00 a.m. every weekday and ended at different times depending on the day of the week.
On Thursdays—the day of the week when Lindsay was injured—the workday officially
ended at 3:00 p.m., although Lindsay typically worked until 3:30 p.m. because she
participated in “ILT.” 2 Lindsay testified that it was not uncommon for her to arrive at
school before 7:00 a.m. and to stay beyond 3:00 or 3:30 p.m. to grade assignments, plan
lessons, set up her classroom, or “connect[] with students in after school activities.”
Lindsay’s employment contract explicitly stated that she would be expected to work
beyond her duty time occasionally:
An important function of a teacher is to work with students on an individual basis and to work with the families. To facilitate this goal, a longer teacher’s day may occasionally be necessary. Moreover, meetings may occasionally necessitate a longer workday. Extension of the teacher’s day shall not be regularly assigned . . . . If frequent or lengthy extension of the workday is required, a teacher shall be paid at the hourly flat direct instruction rate, or an alternative duty schedule shall be arranged by mutual agreement between the teacher and the principal/supervisor.
2 The record does not reveal what the acronym ILT means, but the principal testified that it is a committee.
5 On February 8, 2023, several of Lindsay’s students asked her to play basketball with
them after school. Lindsay had previously attended student basketball practices four or
five times. She had no formal affiliation with the school basketball team, and she did not
receive compensation for participating in practices. Lindsay had never been told not to
attend or participate in extracurricular activities, or that any injuries she sustained during
her participation would not be covered by the school. Numerous teachers at Sullivan
participated in student athletic activities to strengthen their relationships with their
students.
The basketball coach gave Lindsay permission to join a practice and asked her to
come the next day, Thursday, February 9, 2023. On February 9, Lindsay attended
basketball practice after the school day ended. Lindsay explained to the compensation
judge that she participated in the basketball practice in her capacity as a teacher for the
purpose of strengthening her connections with her students.
During the practice, Lindsay was paired with a student for a rebounding drill. At
around 4:00 p.m., Lindsay jumped up for a ball, landed, heard a “pop,” and fell to the
ground.
She later learned that she had ruptured her left ACL. To treat the injury, Lindsay
had surgery and then participated in physical therapy. Lindsay missed more than a month
of work.
Following this incident, Lindsay sought workers’ compensation benefits, but the
school district denied liability. Lindsay filed a claim petition for workers’ compensation
benefits. The school district denied her claim, maintaining that Lindsay’s knee injury did
6 not arise out of and in the course of her employment. The school district asserted, among
other things, that Minnesota Statutes section 176.021, subdivision 9—which excludes from
workers’ compensation liability “[i]njuries incurred while participating in voluntary
recreational programs sponsored by the employer”—excluded the school district from
liability for Lindsay’s injury.
An administrative hearing was held before the workers’ compensation judge on
March 20, 2024. The issues before the compensation judge relevant to this appeal were
whether Lindsay sustained a personal injury arising out of and in the course of her
employment when she tore her ACL, and, if so, whether the exclusion in section 176.021,
subdivision 9, barred her from receiving workers’ compensation benefits.
Following the hearing, the compensation judge concluded that Lindsay’s injury
arose out of and in the course of Lindsay’s employment. The compensation judge
determined that Lindsay’s claim arose out of her employment because there was “a causal
connection between [her] employment[] [as] a math teacher who desires to facilitate better
relationships in the classroom which was explicitly encouraged by her employer” and the
hazard of playing basketball, which caused the injury. Moreover, the compensation judge
determined that Lindsay’s claim occurred “in the course of” employment because of the
time and circumstances of her injury. The compensation judge observed that, because
Lindsay was injured 30 minutes after the end of her workday, her injury occurred within a
reasonable period beyond her working hours. And the compensation judge found that
Lindsay’s participation in the student basketball practice was reasonably incidental to her
employment because she played basketball to foster her relationships with her students,
7 which was consistent with the school’s philosophy, advanced the school’s interests, and
was expressly encouraged by school administration.
After concluding that Lindsay’s injury arose out of and in the course of her
employment, the compensation judge considered the applicability of section 176.021,
subdivision 9, which excludes from liability for compensation injuries that occur during an
employee’s participation in an employer-sponsored recreational program. The
compensation judge determined that the statute applies only to voluntary recreational
programs that are for the benefit of employees. Because Lindsay “participated in the . . .
basketball practice not for her own health, but for her students’ benefit and to foster
connections with them,” the compensation judge concluded that the statutory exclusion did
not apply.
The school district appealed the compensation judge’s decision to the WCCA,
raising the following issues: (1) whether the compensation judge erred in concluding that
section 176.021, subdivision 9, does not bar compensability of Lindsay’s claim;
(2) “[w]hether the compensation judge committed an error of fact and law in determining
that the employee’s claimed personal injury . . . occurred in the course and scope of her
employment”; and (3) “[w]hether the compensation judge’s findings of fact and orders
were clearly erroneous and not supported by substantial evidence in view of the entire
record as submitted.” The WCCA affirmed the compensation judge’s decision. Lindsay
v. Minneapolis Pub. Schs., No. WC24-6567, 2025 WL 408594, at *1 (Minn. WCCA
Jan. 30, 2025). It concluded that section 176.021, subdivision 9, did not bar Lindsay’s
claim for compensation because the afterschool basketball practice was not for the benefit
8 of the employee. Id. at *4–5. The WCCA also concluded that the compensation judge’s
determination that Lindsay’s injury occurred in the course of her employment was not
manifestly contrary to the evidence. Id.
The school district appealed the WCCA’s decision to this court.
ANALYSIS
The school district challenges the WCCA’s decision on two grounds. First, the
school district argues that Lindsay’s injury was not compensable because it did not occur
in the course of her employment. Second, the school district contends that it is not liable
for Lindsay’s injury because Lindsay was injured while participating in an
employer-sponsored voluntary recreational program, and Minnesota Statutes
section 176.021, subdivision 9, shields employers from workers’ compensation liability for
injuries that occur during an employee’s participation in such programs.
We first consider the school district’s argument that Lindsay’s injury did not occur
in the course of her employment. Then, we turn to the applicability of section 176.021,
subdivision 9, to this case.
I.
To be compensable under the Workers’ Compensation Act, an injury must “aris[e]
out of and in the course of employment.” Minn. Stat. § 176.021, subd. 1 (2024). We have
interpreted this statutory language as containing two distinct requirements regarding the
injury: that it be (1) “arising out of” employment and (2) “in the course of” employment.
Dykhoff v. Xcel Energy, 840 N.W.2d 821, 826 (Minn. 2013).
9 The school district does not challenge the WCCA’s affirmance of the compensation
judge’s determination that Lindsay’s injury arose out of her employment. Instead, the
school district argues that the evidence did not establish that Lindsay was injured in the
course of her employment. Our review is therefore limited to the question of whether
Lindsay was injured in the course of her employment. When the underlying facts are
undisputed, we apply a de novo standard of review to determine whether an employee was
injured in the course of employment. See Hohlt v. Univ. of Minn., 897 N.W.2d 777,
780–81, 783–84 (Minn. 2017) (characterizing the compensability of an injury under the
Workers’ Compensation Act as a “question of law” and analyzing whether the employee’s
injury arose out of and in the course of employment without deference to the WCCA). 3
Because the underlying facts in this case are undisputed, we consider de novo whether
Lindsay was injured in the course of her employment. 4
3 When the facts are undisputed, we also apply de novo review to the separate question of whether an injury arises out of employment. Roller-Dick v. CentraCare Health Sys., 916 N.W.2d 373, 376 (Minn. 2018). 4 The school district contends that the compensation judge “erred as a matter of fact and law” as to his ultimate determination that Lindsay’s injury arose out of and in the course of employment and that, similarly, the compensation judge’s factual findings were “clearly erroneous and not supported by substantial evidence.” Before this court, however, the school district does not dispute any of the specific factual findings made by the compensation judge or the WCCA as to the underlying facts. The WCCA stated that the issue of whether Lindsay was injured in the course of her employment is a question of law. See Lindsay, 2025 WL 408594, at *3 (citing Roller-Dick, 916 N.W.2d at 373). The WCCA then stated that “[a] determination of whether an injury occurs within a reasonable time and place is a mixed question of fact and law” and framed its inquiry as a determination of “whether factual findings support a legal conclusion.” Id. Because the underlying facts are undisputed, we must consider whether the WCCA erred as a matter of law when it determined that Lindsay was injured in the course of her employment. See Hohlt, 897 N.W.2d at 780–81, 783–84.
10 “An employee is in the course of employment while providing services to the
employer and also for a reasonable period beyond actual working hours if an employee is
engaging in activities reasonably incidental to employment.” Id. at 783 (citation omitted)
(internal quotation marks omitted). To determine whether an injury occurred “in the course
of” employment, we consider, among other factors, the time of the incident that resulted in
the injury in relation to work hours, the location of the incident that resulted in the injury,
and the circumstances surrounding the injury. See Gibberd ex rel. Gibberd v. Control Data
Corp., 424 N.W.2d 776, 780 (Minn. 1988) (stating that the “in the course of employment”
requirement “refers to the time, place, and circumstances of the incident causing the injury”
(internal quotation marks omitted)); 2 Arthur Larson, Lex K. Larson & Thomas A.
Robinson, Larson’s Workers’ Compensation Law, ch. 12, at 12-1 (2024) (stating that an
injury satisfies the “course of employment” requirement “when it takes place within the
period of the employment, at a place where the employee reasonably may be, and while
the employee is fulfilling work duties or engaged in doing something incidental thereto”).
The school district does not dispute that Lindsay’s injury occurred at Lindsay’s
workplace. This fact supports the conclusion that Lindsay’s injury occurred in the course
of employment. The school district’s arguments focus only on the time of Lindsay’s injury
and the circumstances surrounding the injury. Thus, we limit our analysis to these two
factors.
A.
We first consider the timing of Lindsay’s injury. An employee’s injury is in the
course of employment when it occurs during regular work hours or during “a reasonable
11 period beyond actual working hours if an employee is engaging in activities reasonably
incidental to employment.” Hohlt, 897 N.W.2d at 783 (citation omitted) (internal
quotation marks omitted). In prior decisions, we have recognized that injuries occurring
45 minutes before the official beginning of an employee’s workday and one hour after the
official end of an employee’s workday occurred within a reasonable period beyond actual
working hours. Satack v. State, Dep’t of Pub. Safety, 275 N.W.2d 556, 557 & n.1
(Minn. 1978) (observing that an employee’s fall on the way to work, which occurred about
45 minutes before the start of the workday, was within a “reasonable time before she
commenced work”); Blattner v. Loyal Ord. of Moose, 117 N.W.2d 570, 571, 574
(Minn. 1962) (determining that an employee who fell as he exited his workplace one hour
after his shift had ended “left the premises within a reasonable period of time after his work
terminated” and was entitled to compensation).
Lindsay tore her ACL at approximately 4:00 p.m. on a Thursday. Although the
principal testified that the official workday for teachers at Sullivan ends at 3:00 p.m. on
Thursdays, Lindsay testified that she typically worked until 3:30 p.m. on Thursdays
because she participated in ILT. The compensation judge found that Lindsay sustained her
injury 30 minutes after the end of her formal workday, and the WCCA affirmed that
finding. Before this court, the school district does not contest the timing of Lindsay’s injury
or that the injury occurred about 30 minutes after the end of Lindsay’s workday. 5 Our case
5 The school district’s brief contends that Lindsay’s injury occurred “one hour after the end of her typical workday.” (Emphasis added.) But the school district does not challenge the WCCA’s affirmance of the compensation judge’s finding that the injury occurred within 30 minutes after Lindsay’s workday on the date of the injury.
12 law indicates that an injury occurring 30 minutes after the end of an employee’s workday
is within a reasonable period of working hours. Blattner, 117 N.W.2d at 571, 574.
The school district seeks to distinguish this case from Satack and Blattner, where
we held that employees who were injured arriving at or leaving their workplaces sustained
their injuries within a reasonable time beyond their actual work hours. See Satack,
275 N.W.2d at 557; Blattner, 117 N.W.2d at 571. According to the school district, there
were no circumstances in those cases “taking the employee outside the scope of their
employment.” By contrast, the school district notes, Lindsay was not injured during her
ingress or egress from work; she was injured playing basketball, which is an activity that
is “attenuated” from her employment. This argument is unavailing. The school district
conflates the timing of Lindsay’s injury with the circumstances of the injury, which is a
separate factor that we address below.
We conclude that Lindsay’s injury occurred within a reasonable period beyond her
workday. Therefore, this factor supports a determination that Lindsay was injured in the
course of her employment.
B.
Next, we consider whether the circumstances of Lindsay’s injury indicate that it
occurred in the course of her employment. See Gibberd, 424 N.W.2d at 780. For an injury
to occur “in the course of employment,” the employee must be “engaging in activities
reasonably incidental to employment.” Hohlt, 897 N.W.2d at 783. A review of our case
law reveals that we have not had an opportunity to fully address what qualifies as an
“activit[y] reasonably incidental to employment.” Id. (citation omitted) (internal quotation
13 marks omitted). In Hohlt, we determined that an employee who slipped and fell while
walking to her car, which was parked in the employer’s parking ramp four blocks from the
employee’s worksite, was engaged in an activity that was “reasonably incidental to
employment.” Id. at 784 (citation omitted) (internal quotation marks omitted). But our
case law does not otherwise identify activities that are “reasonably incidental to
employment.”
According to a leading treatise on workers’ compensation law, an employee sustains
an injury “in the course of employment” when the employee was injured while engaging
in “work duties or . . . something incidental thereto” or in “an activity whose purpose is
related to the employment.” 2 Larson et al., Larson’s Workers’ Compensation Law, ch. 12,
at 12-1. “An activity is related to the employment if it carries out the employer’s purposes
or advances its interests directly or indirectly.” Id., ch. 20, at 20-1. Notably, according to
this treatise, the “course of employment” includes “[a]n act outside an employee’s regular
duties which is undertaken in good faith to advance the employer’s interests, whether or
not the employee’s own assigned work is thereby furthered.” 3 Arthur Larson, Lex K.
Larson & Thomas A. Robinson, Larson’s Workers’ Compensation Law, ch. 27 (2024).
We agree with this framework for determining whether an employee’s activity was
“reasonably incidental to employment.” Applying the framework here, we conclude that
Lindsay’s injury occurred while she was engaged in an activity that was reasonably
incidental to employment. The undisputed facts show that Lindsay participated in the
student basketball practice, which was held in the school gym, at the request of her students
and for the purpose of strengthening her relationships with her students. The Sullivan
14 administration expressly encouraged using activities outside of school hours to build
relationships with students; indeed, the failure to build relationships with students would
be reflected in a teacher’s formal evaluation. And Lindsay’s employment contract
explicitly stated that the expectation to work with students would occasionally require
working beyond her normal hours.
The school district contends that Lindsay’s participation in the practice was not
reasonably incidental to her employment because it was neither required nor “even
remotely related to her work as a math teacher.” Instead, the school district argues,
Lindsay’s participation was a voluntary choice beyond the scope of her role. The school
district’s focus is too narrow, however. Lindsay participated in the basketball practice to
strengthen her relationships with students. Under Sullivan’s approach to teaching,
strengthening relationships with students was part of Lindsay’s work as a teacher.
Lindsay’s participation in the basketball practice was within the scope of her regular
duties and advanced her employer’s interests. Thus, her injury was reasonably incidental
to her employment.
* * *
The undisputed facts show that Lindsay’s injury occurred about 30 minutes after
work, within a reasonable time period after the official end of her workday; that Lindsay
was injured at the school, the location of her employment; and that Lindsay was injured
while engaged with students in an activity reasonably incidental to her employment as a
teacher. Neither party points to any other facts that we should consider in analyzing
whether Lindsay’s injury occurred in the course of her employment. Given these
15 undisputed facts, we conclude as a matter of law that the injury occurred “in the course of”
Lindsay’s employment. Accordingly, the WCCA did not err in affirming the compensation
judge’s determination that Lindsay’s injury occurred in the course of employment and was
therefore compensable.
II.
We next address whether Minnesota Statutes section 176.021, subdivision 9, barred
Lindsay’s claim for workers’ compensation benefits. Section 176.021, subdivision 9,
excludes from liability injuries incurred while participating in voluntary
employer-sponsored recreational programs. The school district argues that Lindsay’s
injury is not compensable because she injured her knee during a voluntary
employer-sponsored recreational program—a school basketball practice.
We begin our analysis with the language of the statute. Section 176.021,
subdivision 9, provides:
Employer responsibility for wellness programs. Injuries incurred while participating in voluntary recreational programs sponsored by the employer, including health promotion programs, athletic events, parties, and picnics, do not arise out of and in the course of the employment even though the employer pays some or all of the cost of the program. This exclusion does not apply in the event that the injured employee was ordered or assigned by the employer to participate in the program.
We previously considered the meaning of the word “voluntary” as used in
section 176.021, subdivision 9, concluding that it means “[d]one or undertaken of one’s
own free will or done willingly and without constraint or expectation of reward.” Shire v.
Rosemount, Inc., 875 N.W.2d 289, 296 (Minn. 2016) (alteration in original) (citation
16 omitted) (internal quotation marks omitted). 6 But we have not interpreted the phrase
“voluntary recreational programs sponsored by the employer.” We take this opportunity
to do so.
The interpretation and application of workers’ compensation statutes present
questions of law that we review de novo. Profit v. HRT Holdings, 987 N.W.2d 575, 579
(Minn. 2023). “The purpose of statutory interpretation is to ascertain the intention of the
Legislature.” Shire, 875 N.W.2d at 292. “When interpreting a statute, we first examine
the statutory language to determine whether the statute is ambiguous, that is, whether the
statute is susceptible to more than one reasonable interpretation.” Profit, 987 N.W.2d
at 579–80 (citation omitted) (internal quotation marks omitted). If we determine that the
statute is unambiguous, we apply its plain meaning. Id. at 580. But if “more than one
meaning is reasonable within [the] context” of the statute, the statute is ambiguous and we
may apply the canons of construction to ascertain the Legislature’s intent. State v.
Henderson, 907 N.W.2d 623, 626 (Minn. 2018); see also Minn. Stat. § 645.16 (2024)
(providing guidance on ascertaining legislative intent).
The school district argues that the compensation judge and the WCCA erred in
interpreting section 176.021, subdivision 9, to require that voluntary employer-sponsored
6 In Shire, an employee injured his ankle playing laser tag at an employee-recognition event that was held during the employee’s normal work hours. 875 N.W.2d at 290–91. Before the event, the employer informed employees that they could either attend the event, use vacation time, or request unpaid leave. Id. at 290. We held that section 176.021, subdivision 9, did not exclude the employee’s injury from Workers’ Compensation Act coverage because the employee could only opt out of the event by forfeiting compensation or vacation benefits. Id. at 294–95. Thus, the event was not “voluntary.” Id.
17 recreational programs be for the benefit of employees. It contends that the language of the
statute contains no such requirement. Moreover, the school district maintains, considering
the component terms of the phrase “voluntary recreational program sponsored by the
employer” shows that the statute does not include a requirement that these programs benefit
employees. In contrast to the WCCA’s interpretation, the school district asserts that
school-sponsored basketball practices are plainly voluntary recreational programs under
section 176.021, subdivision 9. The school district points to the statute’s nonexhaustive
list of voluntary recreational programs, which includes “athletic events,” to support this
argument.
On the other hand, Lindsay urges us to interpret the statute as a whole, and not in its
component parts. Using this approach, she argues that section 176.021, subdivision 9,
applies only to programs geared toward employees. Lindsay maintains that the headnote
to subdivision 9—“Employer responsibility for wellness programs”—makes clear that the
exclusion refers only to wellness programs, i.e., programs that aim to improve employees’
health and well-being. Additionally, Lindsay contends that the examples of voluntary
recreational programs that are listed in the statute must be read in conjunction with the
headnote to section 176.021—“Application to Employers and Employees.” According to
Lindsay, reading that headnote in conjunction with the listed examples makes clear that the
subdivision only includes “health promotion programs, athletic events, parties, and
picnics” for employers and employees, not to similar programs for students. 7
7 In further support of her interpretation, Lindsay cites a WCCA decision, Hansen v. Wyatt Ready Mix, 44 Minn. Workers’ Comp Dec. 276 (WCCA 1990). There, the WCCA
18 We agree with Lindsay that there is only one reasonable interpretation of
section 176.021, subdivision 9: the exclusion applies only to employer-sponsored
programs for the benefit of employees.
Our analysis begins by focusing on the word “recreational” in the statutory
exclusion for “[i]njuries incurred while participating in voluntary recreational programs
sponsored by the employer.” Minn. Stat. § 176.021, subd. 9. The Workers’ Compensation
Act does not define this word. See Minn. Stat. § 176.011 (2022) (defining terms under the
Workers’ Compensation Act). When interpreting words that are not defined by a statute,
we may look to dictionary definitions to ascertain their common and ordinary meanings.
State v. Thonesavanh, 904 N.W.2d 432, 436 (Minn. 2017). Dictionary definitions of the
word “recreation” support Lindsay’s argument that employer-sponsored “recreational
programs” are programs intended to benefit employees. One dictionary defines
“recreation” as the “[r]efreshment of one’s mind or body after work through activity that
amuses or stimulates; play” and “[a]n activity that provides such refreshment.” The
American Heritage Dictionary of the English Language 1470 (5th ed. 2018) (emphasis
added). Another dictionary defines “recreation” as “refreshment of the strength and spirits
after toil” and “a means of getting diversion or entertainment.” Webster’s Third New
International Dictionary of the English Language Unabridged 1899 (2002). Both of these
definitions reflect that “recreation” means refreshment to those who work. Given the
concluded that the term “recreational programs” in section 176.021, subdivision 9, refers only to “programs sponsored by employers to promote employee health and fitness; psychological or social well-being; and goodwill between an employer and their employees.” Id. at 278.
19 common and ordinary meaning of the word “recreation,” the term “recreational programs”
can only reasonably refer to programs that are for the benefit of employees.
This conclusion is underscored by the statute as a whole. See Henderson,
907 N.W.2d at 625 (“We read a statute as a whole and give effect to all of its provisions.”).
As noted, section 176.021, subdivision 9, lists four examples of a “recreational program”:
“health promotion programs, athletic events, parties, and picnics.” Each of these examples
suggests that the Legislature intended for “recreational programs” to refer to
employer-sponsored programs for employee recreation. See In re SIRS Appeal by Nobility
Home Health Care, Inc., 999 N.W.2d 843, 857 (Minn. 2024) (explaining that we should
give words grouped in a list related meanings). The decision to include “parties” and
“picnics” particularly supports this legislative intent. Parties and picnics are commonly
understood to be enjoyable leisure activities.
We are further persuaded by Lindsay’s argument that the Legislature’s reference to
“wellness programs” in the headnote to section 176.021, subdivision 9, shows that
“recreational programs” means programs that benefit employees. Generally, we do not
consider headnotes when interpreting statutes. See Buzzell v. Walz, 974 N.W.2d 256, 264
n.7 (Minn. 2022) (citation omitted); see also Minn. Stat. § 645.49 (2024) (stating that
headnotes are of no persuasive value). But we have observed that a headnote may be
relevant to our interpretation of a statute “if present in the original legislative process.”
S.M. Hentges & Sons, Inc. v. Mensing, 777 N.W.2d 228, 231 n.1 (Minn. 2010) (concluding
that a headnote added years after a provision’s enactment “was not part of the original
legislative process” and therefore was “not relevant” to the court’s analysis). The headnote
20 to section 176.021, subdivision 9, which states, “Employer responsibility for wellness
programs,” was present in the original legislative process; the Legislature itself drafted the
headnote before passing the session law. See Act of May 22, 1985, ch. 234, § 4,
1985 Minn. Laws 739, 745 (codified as amended at Minn. Stat. § 176.021, subd. 9). And
the Legislature’s use of the term “wellness programs” in the headnote further shows that
subdivision 9 concerns programs that benefit employees. As Lindsay observes, the word
“wellness” connotes activities that support and benefit a person’s well-being.
Finally, we are convinced that the Legislature’s use of the word “voluntary”
indicates that voluntary employer-sponsored recreational programs are programs that
benefit employees. We have already interpreted the word “voluntary” in this context as
meaning “[d]one or undertaken of one’s own free will or done willingly and without
constraint or expectation of reward.” Shire, 875 N.W.2d at 296 (alteration in original)
(citation omitted) (internal quotation marks omitted). The fact that employees are not
required to participate in the recreational programs referenced in section 176.021,
subdivision 9, strongly suggests that such programs are for the benefit of employees and
not the employer.
The school district argues that the reference to “athletic events” includes any athletic
activity, which would encompass the afterschool basketball practice where Lindsay
sustained her injury. We disagree. Under the associated words canon—noscitur a sociis—
“words grouped in a list should be given related meanings.” 8 Nobility, 999 N.W.2d at 857
8 We may apply the associated words canon in interpreting statutes that are either unambiguous or ambiguous. Nobility, 999 N.W.2d at 858.
21 (citations omitted) (internal quotation marks omitted); see also County of Dakota v.
Cameron, 839 N.W.2d 700, 709 (Minn. 2013) (defining and applying the associated words
canon, which provides that “a word is given more precise content by the neighboring words
with which it is associated” (citation omitted) (internal quotation marks omitted)). The
inclusion of “health promotion programs,” “parties,” and “picnics” in the same list as
“athletic events” indicates that the “athletic events” referenced in section 176.021,
subdivision 9, include only recreational athletics for the benefit of employees, such as
certain employer-sponsored athletic teams or races.
We conclude that a voluntary employer-sponsored recreational program under
section 176.021, subdivision 9, is a program for the benefit of employees. Applying this
interpretation here, we reject the school district’s argument that the student basketball
practice at Sullivan was a voluntary employer-sponsored recreational program within the
meaning of the statute.
Accordingly, section 176.021, subdivision 9, does not exclude compensation for
Lindsay’s injury. The WCCA therefore did not err in affirming the compensation judge’s
determination that Lindsay’s injury was compensable under the Workers’ Compensation
Act.
CONCLUSION
For the foregoing reasons, we affirm the decision of the Workers’ Compensation
Court of Appeals.