Schmitz v. U.S. Steel Corp.

Why This Case Matters

Schmitz v. U.S. Steel Corp. strengthened protections for Minnesota workers who file—or consider filing—workers’ compensation claims. The decision established two important principles: first, that employees bringing retaliatory discharge claims under Minn. Stat. § 176.82 have a constitutional right to a jury trial; and second, that an employer does not need to actually fire an employee for retaliation to be actionable—even a threat of discharge can give rise to a claim.

The Facts

Schmitz was an employee of U.S. Steel Corporation who was injured on the job. When Schmitz sought to file a workers’ compensation claim for the injury, a supervisor threatened to discharge Schmitz for doing so. Schmitz brought suit under Minn. Stat. § 176.82, which prohibits employers from discharging or threatening to discharge an employee for seeking workers’ compensation benefits.

The case raised two key questions: whether Schmitz was entitled to a jury trial on the retaliatory discharge claim, and whether a threat of discharge—without an actual termination—was sufficient to support a claim under the statute.

What the Court Decided

The Minnesota Supreme Court ruled in favor of Schmitz on both issues. On the jury trial question, the court held that retaliatory discharge claims under § 176.82 are legal claims for damages, and the Minnesota Constitution guarantees the right to a jury trial for such claims. This meant that employees could have their cases decided by a jury of their peers rather than by a judge sitting alone.

On the question of whether a threat alone was enough, the court looked carefully at the language of § 176.82, which prohibits both discharge and threats to discharge an employee for seeking workers’ compensation benefits. The court held that the statute means what it says: a supervisor’s threat to fire an employee for filing a workers’ compensation claim is independently actionable. The employee does not need to wait until actually being terminated to seek relief. This interpretation supports the statute’s purpose of ensuring that injured workers can pursue the benefits they are entitled to without fear of retaliation.

What This Means for You

• Threats count, not just termination: If a supervisor or employer threatens to fire you for filing a workers’ compensation claim, that threat alone may be enough to support a legal claim under Minn. Stat. § 176.82. You do not have to wait until you are actually terminated.
• You have a right to a jury trial: If you bring a retaliatory discharge or threat claim seeking damages, you are constitutionally entitled to have a jury hear your case.
• Filing a workers’ comp claim is protected: Minnesota law specifically protects your right to file a workers’ compensation claim for a workplace injury. Your employer cannot punish you for exercising that right.
• Document any threats immediately: If a supervisor threatens adverse action because of a workers’ compensation claim, write down exactly what was said, when, where, and who was present. Report the threat to human resources in writing. These records are essential to proving your claim.