## Facts

- Ernest M. Hyett worked for Northwestern Hospital for Women and Children as a fireman in charge of the hospital’s heating plant.
- While acting within the course of employment, Hyett suffered a single accident that caused:
  - a temporary work-disabling injury, for which the hospital paid $44 in compensation; and
  - a separate injury to his left pudic nerve that permanently destroyed its function and rendered him permanently impotent.
- The impotence did not disable Hyett from performing his job and did not affect his earning capacity.
- Hyett brought a common-law negligence action against the hospital seeking damages solely for the non-disabling injury (permanent impotence).
- The hospital asserted that, because both parties were subject to the Minnesota Workmen’s Compensation Act, the statutory remedy was exclusive.
- The district court sustained Hyett’s demurrer to the hospital’s exclusivity defense, and the hospital appealed.

## Issues

1. Whether an employee covered by the Minnesota Workmen’s Compensation Act may maintain a common-law negligence action against the employer for a non-disabling injury arising from the same accident that also caused a compensable disability.

## Decision

- The Minnesota Supreme Court reversed the order sustaining the demurrer.
- The court held that, where a single work accident produces both a disability compensable under the Act and additional associated harms not amounting to disability, the employee’s remedy is limited to the Act.
- The employee may not sue at common law for the non-disabling component of the injury.

## Legal Principles

- For covered employees injured in the course of employment, the workers’ compensation remedy is exclusive to the extent the Act provides compensation for the injury.
- When one work-related “particular injury” results partly in compensable disability and partly in other harms (e.g., disfigurement, pain and suffering, or loss of bodily function without wage-loss disability), the employee cannot split the consequences and sue in negligence for the non-disabling harms.
- If non-disabling elements of damage are to be compensable, that expansion must come from legislative amendment, not judicial authorization of common-law actions.

## Conclusion

Because Hyett’s accident caused a compensable disability within the workers’ compensation system, the Act barred a separate negligence suit against the employer for the additional non-disabling harm of permanent impotence arising from the same accident.


Hyett v. Nw. Hosp. for Women & Children, 147 Minn. 413, 180 N.W. 552 (Minn. 1920)