SUPREME COURT OPINION SUMMARY – Rowe v. City Of Minneapolis

SUPREME COURT – JULY 22, 2026
No. A24-1465

A police officer sought workers' compensation benefits after having been diagnosed with post-traumatic stress disorder (PTSD). The officer was diagnosed with PTSD by a licensed psychologist, who relied on the DSM-5 in providing this diagnosis. In Minnesota, a diagnosis of a mental impairment such as PTSD is, by statute, presumed to be work related. See Minn. Stat. § 176.011, subd. 15(e). However, an employer and insurer may rebut this presumption by a showing of "substantial factors." Id.

In this case, the employer attempted to rebut the presumption in part by obtaining an expert report from Dr. Kenneth Young. In his report, Dr. Young indicated he believed that the employee did not meet the criteria for PTSD as described in the DSM-5. Notably, neither Dr. Young's report nor the report of the employee mentioned the DSM-5-TR, which is a text revision to the DSM-5 and the most recent version of the DSM. The compensation judge ultimately adopted Dr. Young's opinion, determined the employer had rebutted the presumption, and denied the employee's claim. The employee appealed.

The Workers' Compensation Court of Appeals (WCCA) reversed the compensation judge, determining that, because Minn. Stat. § 176.011, subd. 15(d) requires that an employee present a diagnosis of PTSD "as described in the most recently published edition of the [DSM]," that the evidence used to rebut the presumption must also be based on the most current version of the DSM.

The case was then appealed to the Minnesota Supreme Court, who reversed the WCCA. The Supreme Court determined that the WCCA erred when it concluded that an IPE report based on the most recent edition of the DSM is the only proof that can constitute "substantial factors" to rebut the presumption. The court explained that are, in fact, multiple ways for an employer to rebut the presumption. By way of example, they highlighted that a presumption could be rebutted by expert opinions undermining the methodology of, or pointing out errors in, an expert opinion diagnosing the employee with PTSD. The Supreme Court noted that, while an IPE opinion based on a outdated version of the DSM may very well have less probative value than an opinion based on the most recent version of the DSM, a compensation judge is not required to exclude the employer's IPE as a matter of law solely because it relied on an outdated edition of the DSM, and that such an opinion may properly be considered by a compensation judge in considering whether an employer has rebutted the presumption by "substantial evidence."

In the end, this decision reinforces the long-established principle in Minnesota that compensation judges are afforded great discretion in determining which among multiple expert opinions to adopt, and that judges are permitted to consider a wide range of potential evidence in assessing whether an employer and insurer are able to rebut the statutory presumption in PTSD cases.

Summary prepared by Attorney Jason Heikkinen