A lawsuit brought by a fitness club referee who was assaulted during a basketball game was properly dismissed because his claims are barred by the exclusive remedy provisions of the state’s workers compensation law, a Minnesota appellate court ruled Monday.
In Ayeni v. Life Time Group Holdings Inc., the Minnesota Court of Appeals ruled that injuries sustained by employee Philip Ayeni during a workplace altercation arose out of and in the course of employment, placing his injuries within the scope of the state’s Workers’ Compensation Act.
Mr. Ayeni was officiating a basketball game at a Life Time fitness facility when three members, who had previously been suspended for violent behavior but later reinstated, attacked him after disputing a foul call, the ruling states. He suffered injuries, including a concussion and facial lacerations.
Mr. Ayeni filed suit alleging assault, negligent supervision and related claims. The employer moved to dismiss, arguing that workers compensation provided the exclusive remedy. A lower court agreed, and the appellate court affirmed.
On appeal, Mr. Ayeni argued that two exceptions to exclusivity should apply: the “assault exception,” which allows civil claims when an attack is motivated by personal reasons unrelated to employment, and the intentional-injury exception.
The court rejected both arguments, finding the assault was directly tied to Mr. Ayeni’s job duties, noting the altercation stemmed from a foul call made during a game he was officiating. Because the incident was not “wholly unconnected” to his employment, the assault exception did not apply.
The court also determined there was no evidence the employer acted with deliberate intent to cause injury – a high bar required to trigger the intentional-injury exception. Allegations that the company knew of prior member misconduct but failed to prevent the incident amounted to negligence, not intent, the court said.