Landmark Decision Affirms Work Injury Coverage for Educators Engaging with Students Beyond School Hours
In a groundbreaking decision that will impact teachers, educators, and paraprofessionals across Minnesota, the Minnesota Supreme Court has affirmed that work injuries sustained during after-school activities can be covered by workers’ compensation. The October 22, 2025, decision in Lindsay v. Minneapolis Public School District represents a significant victory for educators who go above and beyond their formal duty hours to build relationships with students.
At Mottaz & Sisk Injury Law, we’re proud to have represented Erin Lindsay, a dedicated middle school math teacher whose commitment to her students led to a compensable workplace injury—and ultimately, this important precedent for teachers throughout Minnesota.
The Case: When Dedication Leads to Injury
Erin Lindsay had been a math teacher with Minneapolis Public Schools since 2011, working at Sullivan STEAM Magnet School since 2020. Like countless educators across Minnesota, Lindsay understood that effective teaching extends beyond formal classroom instruction. At Sullivan, a school emphasizing project-based learning and social-emotional development, teachers were explicitly encouraged to build strong relationships with their students.
On February 9, 2023, Lindsay did what many dedicated teachers do—she participated in an after-school activity with her students. Several of her students had asked her to play basketball with them during practice, and she accepted their invitation. At approximately 4:00 p.m., just 30 minutes after her formal workday ended, Lindsay jumped for a rebound during a drill and heard a devastating “pop.” She had ruptured her ACL, requiring surgery, extensive physical therapy, and missing more than a month of work.
When Lindsay sought workers’ compensation benefits for this work injury, the school district denied her claim, arguing that she was participating in a voluntary recreational activity outside the scope of her employment.
Why This Case Matters for Teachers and Educators
The Supreme Court’s decision recognizes a fundamental truth about modern education: teaching isn’t confined to a classroom or limited to formal duty hours. For teachers, educators, and paraprofessionals across Minnesota, this ruling confirms that when you’re building relationships with students as part of your professional responsibilities, you’re still acting within the course of your employment—even during after-school activities.
Recognizing the Reality of Teaching
The Court examined the undisputed facts carefully:
- Sullivan’s mission statement emphasized “cultivation of strong relationships in collaboration with students”
- Teachers were evaluated on their ability to develop relationships with students and families
- The school administration explicitly encouraged teachers to participate in student activities outside normal school hours
- Lindsay’s employment contract acknowledged that working with students individually and with families would “occasionally necessitate a longer workday”
- Building relationships with students was not optional—it was an expectation reflected in teacher evaluations
The Court recognized what teachers have always known: relationship-building is not separate from teaching—it is teaching. As the decision noted, 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.”
Breaking Down the Legal Victory
The Supreme Court addressed two critical legal questions that will guide future work injury claims for educators:
1. “In the Course of Employment“
For a work injury to be compensable, it must arise “out of and in the course of employment.” The school district argued that Lindsay’s injury didn’t occur “in the course of” her employment because she was playing basketball, not teaching math.
The Court disagreed, examining three key factors:
Time: Lindsay was injured approximately 30 minutes after her workday officially ended. The Court held this was clearly “within a reasonable period beyond her workday,” citing precedents that had approved injuries occurring up to an hour after the workday ended.
Place: The injury occurred at Lindsay’s workplace—the school gymnasium. This factor strongly supported compensability.
Circumstances: Most importantly, Lindsay was engaged in an “activity reasonably incidental to employment.” The Court adopted a framework that asks whether the employee was engaged in activity “whose purpose is related to the employment” and that “advances [the employer’s] interests directly or indirectly.”
Lindsay’s participation in the basketball practice checked every box:
- It was undertaken to strengthen student relationships
- This relationship-building was explicitly required and evaluated by her employer
- It advanced the school’s educational mission and interests
- It fell within activities her employment contract anticipated
2. The “Recreational Program” Exclusion
The school district also argued that even if the injury occurred during employment, Minnesota law excludes injuries that happen during “voluntary recreational programs sponsored by the employer.”
In a crucial interpretation, the Supreme Court held that this exclusion applies only to recreational programs that benefit employees—things like company softball teams, wellness programs, employer-sponsored parties, or picnics. It does notapply to student activities that teachers participate in as part of their professional responsibilities.
The Court’s reasoning was compelling: the word “recreational” means “refreshment of one’s mind or body after work”—it refers to programs for the benefit of workers, not programs that further the employer’s mission. Lindsay wasn’t playing basketball for her own recreation or health; she was there as a teacher, building relationships with her students.
What This Means for Minnesota Educators
This decision provides important protections for teachers, educators, and paraprofessionals who participate in after-school activities:
Coverage for After-School Activities
If you’re participating in student activities as part of your professional role—whether coaching, supervising clubs, attending student events, or engaging in other relationship-building activities—work injuries sustained during these activities should be covered by workers’ compensation.
Reasonable Time After School Hours
Injuries occurring within a reasonable period after your workday ends (the Court suggested up to an hour) can still be “in the course of employment” if you’re engaged in work-related activities.
Focus on Your Role, Not the Activity
The key question isn’t whether the activity itself seems “educational”—it’s whether you’re participating as part of your professional responsibilities. A math teacher playing basketball with students to build relationships is acting as a teacher, not as a recreational athlete.
Protection for Your Professional Commitment
Many educators feel pressure to participate in after-school activities, attend student events, and go beyond their formal duty hours. This decision confirms that when schools expect and evaluate teachers on relationship-building, and when teachers respond to those expectations, they’re entitled to workers’ compensation protection.
When Work Injuries Occur: Know Your Rights
If you’re a teacher, educator, or paraprofessional who has suffered a work injury during after-school activities, you have important rights:
Report Your Injury Immediately: Notify your employer as soon as possible after any work-related injury, even if you’re unsure whether it will be covered.
Seek Medical Treatment: Your health is the priority. Get appropriate medical care and follow your treatment plan.
Document Everything: Keep records of the circumstances of your injury, including why you were participating in the activity, any encouragement or expectations from administration, and how the activity related to your professional responsibilities.
Don’t Accept a Denial Without Fighting: Insurance companies and school districts may initially deny claims for after-school activity injuries. The Lindsay case shows that these denials can be successfully challenged.
Get Experienced Legal Help: Workers’ compensation cases involving educators can be complex, involving questions about the scope of employment, institutional expectations, and statutory exclusions.
Mottaz & Sisk: Fighting for Injured Educators
At Mottaz & Sisk Injury Law, we understand the unique challenges facing teachers and school staff who suffer work injuries. We know that educators are often expected to work beyond their formal hours, that relationship-building with students is essential to modern teaching, and that these professional commitments can sometimes lead to injuries.
The Lindsay victory demonstrates our commitment to fighting for injured workers—even when insurance companies and employers deny valid claims. We took this case from the workers’ compensation court through the appellate process to the Minnesota Supreme Court because we believed in our client and understood the importance of this issue for educators across the state.
If you’re a teacher, educator, or paraprofessional who has been injured during after-school activities, student events, or other work-related functions—and your workers’ compensation claim has been denied or challenged—contact us. We offer free consultations for injured workers, and we only get paid if we win your case.
Conclusion: A Victory for Dedicated Educators
The Lindsay decision recognizes and protects the reality of modern education in Minnesota. Teachers aren’t just classroom instructors working formal hours—they’re professionals who build relationships with students, attend after-school activities, and go above and beyond to fulfill their educational mission.
When educators suffer work injuries while engaged in these professional activities, they deserve workers’ compensation protection. Thanks to the Minnesota Supreme Court’s decision, they now have important legal precedent confirming that right.
At Mottaz & Sisk Injury Law, we’re proud to have secured this victory for teachers and educators across Minnesota. If you’ve been injured at work, contact us to learn how we can help protect your rights and secure the benefits you deserve.
Mottaz & Sisk Injury Law represents injured workers in workers’ compensation cases throughout Minnesota. Contact us for a free consultation about your work injury claim.
