Linda J. Brown v. Ind School District #2311, Department of Employment and Economic Development

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-1339

Linda J. Brown,
Relator,

vs.

Ind School District #2311,
Respondent,

Department of Employment and Economic Development,
Respondent.

Filed August 10, 2026
Reversed
Harris, Judge

Department of Employment and Economic Development
File No. 5111188-5

Thomas H. Boyd, Haley N. Mercer (certified law student practitioner), Winthrop &
Weinstine, P.A., Minneapolis, Minnesota (for relator)

Ind School District #2311, Clearwater, Minnesota (respondent employer)

Melannie M. Markham, Keri A. Phillips, Minnesota Department of Employment and
Economic Development, St. Paul, Minnesota (for respondent department)

Considered and decided by Johnson, Presiding Judge; Harris, Judge; and
Rasmusson, Judge.

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NONPRECEDENTIAL OPINION
HARRIS, Judge
In this unemployment -benefits appeal, relator challenges the decision of the
unemployment-law judge (ULJ) that she was ineligible for unemployment benefits because
she quit her job and did not meet any statutory exception to make her eligible. Relator
argues that she met one of the statutory exceptions to ineligibility based on a quit—the
serious-illness exception. We reverse.
FACTS
The following summarizes the ULJ’s written factual findings along with the record
evidence relevant to the issues on review.
Relator Linda J. Brown was employed by respondent Ind School District #2311 (the
district) and worked at Clear Brook Elementary & Senior High (the school) from
September 2016 to March 2024. Brown worked in various roles at the school but had most
recently worked as a full-time art teacher.
In August 2021, Brown requested reasonable accommodations for the 2021-20 22
school year and provided the district with documentation from her physician indicating that
she was immuno-compromised.
1 The physician also stated that her “compromised immune
system [was] further complicated due to her age.” To mitigate the risk of contracting
COVID-19, Brown submitted three accommodations requests. First, Brown requested that

1 The first reasonable accommodation request was made after the district had resumed
operations for in-person schooling following the emergence of the COVID-19 pandemic
and subsequent emergency shutdown that began in early 2020.

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students in her classes wear masks; the district denied this request. Second, she asked that
students in her class follow social-distancing protocols from herself and others; the district
denied this request because of the class sizes. Brown also requested to work remotely,
which the district denied as well. Finally, Brown requested a medical leave of absence
until the end of the first semester, and the district granted her leave.
Throughout that semester, Brown attempted to negotiate with the district on
accommodations, focusing on requiring that students in her class wear masks. Because the
parties could not reach an agreement, Brown’s leave of absence was extended into the
following semester. Brown returned to full-time in-person work in March 2022. In May,
Brown contracted COVID-19 and became very ill. Brown required hospitalization in early
June and had a slow recovery. Brown was later diagnosed with long COVID syndrome
and subsequently filed a workers’ compensation claim.
Throughout the 2022-2023 school year, Brown worked six-hour days, five days per
week. The district removed a class period from Brown’s schedule, which allowed her to
start the day during second hour at approximately 9:15 a.m., approximately 50 minutes
after most teachers began their workday.
Brown struggled to work the six-hours-per-day, five-days-per-week schedule. She
testified that, as a teacher, a six-hour day is never just six hours. As part of her submission
to the ULJ, Brown explained that the nature of her work often required working hours
beyond the scheduled hours contained in her contract with the district. She explained that
grading papers, preparing the classroom, obtaining art supplies, and cleaning up the studio
cannot be completed within the allotted class time.

4
The district reprimanded Brown in January 2023. During one of her classes, Brown
brought 19 of her students to the school’s main office, where she confronted the principal
and expressed her dissatisfaction with current and future student enrollment numbers in
her art classes. S he complained that the anticipated student enrollment for her seventh
period art class was too large. Brown also asked and encouraged her students to share their
experiences in art class in front of the principal. The district found the encounter to be
unprofessional, created an uncomfortable working environment, and that it was
inappropriate to engage students as a means of communicating employment disagreements
and concerns.
In July 2023, Brown requested an accommodation in the form of a reduced work
schedule. She requested to work up to four hours per day, five days per week, with one of
those hours serving as class-preparation time. Her request consisted of a letter from her
physician stating:
She especially has fatigue secondary to long COVID syndrome
and insomnia. These conditions have even worsened since my
last letter. She is still able to perform essential functions of
teaching but with restrictions as follows. She may work up to
4 hours 5 days a week. I will recommend that 1 of these hours
be a preparation for class time hour. Her me dical conditions
may change during the school year so that we can relax these
restrictions[,] but for now they should be active through the
school year until further notice.

The superintendent responded that the restrictions as recommended by her physician
were not reasonable and would not be accommodated. He explained that working four
hours, five days per week resulted in a part- time schedule, with Brown working three
“class” hours, even though the district needed a full-time art teacher . The superintendent

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also stated that if the district granted her accommodations, it would need to locate and hire
an additional part-time art teacher , which he believed would not be possible given his
knowledge and experience in the labor market.
In August 2023, Brown responded to the superintendent’s letter, and further
inquired about her accommodations and supply budget for the upcoming school year. She
indicated that she, along with another art teacher at the school, approached the principal
earlier that year about a “job share” for the art classes. She also stated, “Since you have
rejected my physician’s recommendations, is it safe to assume that the less-restrictive
accommodations from last year (a 6 hour day, class sizes limited to 20 students, etc.) will
remain in place for 2023-24 or will you require yet another letter from my doctor?”
In response to Brown’s inquiry, the superintendent stated that a job-share
accommodation was not possible because the other art teacher had accepted a full-time
position with the school for the upcoming year. He also indicated that the district believed
Brown was capable of working eight-hour days, five days per week based on a recent
independent medical examination, and that the district was not required to provide the
accommodation. Still, the district approved Brown’s request to work six-hour days, five
days per week, just as she had worked the year prior. Brown was scheduled to teach five
courses per day for the upcoming semester. At the end of the letter, the superintendent
wrote, “Please confirm whether you plan to return to school this fall.”
The district’s human resources (HR) manager testified that Brown did not reply to
the letter or confirm with the district whether she planned to return. Instead, “[s]he just
showed up on the first day and began working those accommodations.” Brown testified

6
that she communicated her intent to return to work “probably through telephone.” Brown
clarified that she did not agree with the superintendent’s letter but returned to work because
she “had no choice.”
In December 2023, Brown wrote a letter to the superintendent, again requesting a
reduced work schedule or a “job share position” with the other art teacher for the following
semester. Brown indicated that she was “highly qualified, certified and has already
indicated her sincere interest in a job share position.” She also contested the independent
medical examiner’s recommendation that she could work eight hours a day.
Brown testified that she had difficulty maintaining the six-hours-per-day, five-days-
per-week schedule that semester. By this point, her workers’ compensation claim from
2022 still had not settled, and Brown struggled with ongoing medical bills that stemmed
from her COVID-19 complications. Brown testified that after various discussions, she
determined she had three options. First, she could take her workers’ compensation claim
to trial. Her counsel indicated that it would take a long time to litigate and would be
difficult to win because she would have to find an employment attorney and because there
was little scientific research on long COVID syndrome. Second, she could negotiate a
separation agreement with the district.
2 And third, she could continue working at the
school with no guarantee that she could maintain the six-hours-per-day schedule.

2 The record is unclear about who initially proposed the separation agreement. The HR
manager testified that the separation agreement was “part of the workers’ comp[ensation]
case.” She added, “And in amongst communications between [Brown’s] attorney and our
attorneys, the conversation was struck up in regard to a potential separation agreement,
which would then effectively end the workers’ comp[ensation] case.”

7
Brown testified that she loved her job, her students, peers, and colleagues. She
noted that she did not want to leave. She felt “concerned, exhausted, anxious, stressed,
[and] depressed.” Even with the six-hours-per-day schedule, her exhaustion caused “poor
concentration, brain fog, irritability, and a decreased level of patience.” Even though she
loved teaching, she knew that continuing to do so “was detrimental to [her] health and well-
being.” Brown chose to resign. She testified, “It was with much soul-searching and a great
deal of hesitation and sadness that I decided to have my attorney begin to negotiate a
separation agreement.”
On December 12, 2023, the parties entered into a separation agreement.3 As part of
that agreement, Brown requested $65,000 in severance pay, agreed to withdraw or waive
all claims against the district and voluntarily resign employment with the district. The
parties settled the workers’ compensation claim and reached a separation agreement.
Brown resigned on March 1, 2024.
In October 2024, Brown filed for unemployment benefits with the department of
employment and economic development (DEED). She indicated that the reason for
quitting was because the superintendent “was dishonest, unethical, difficult to work with
and did things or refused to work fairly with me.” DEED determined that Brown was

3 Approximately one week after receiving the proposed separation agreement, the district
received a letter from Brown’s physician, dated December 8, 2023, reiterating her need for
accommodations because of her chronic health conditions. Because the district was
actively engaged in negotiating a separation agreement with Brown, it did not communicate
any further about her accommodation request.

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ineligible for benefits “because of a personality conflict with a supervisor or co-worker.”
Brown appealed DEED’s initial determination of ineligibility.
Following an evidentiary hearing in January 2025, a ULJ issued its findings of fact
and decision, and concluded that Brown quit her employment because a “serious illness
made it medically necessary to quit.” The district submitted a request for reconsideration,
which the ULJ granted; it then set aside the initial decision and scheduled another hearing.
At that hearing, Brown testified that “it seemed like” she had to quit in order to settle the
workers’ compensation claim. She believed that “no matter what [she] did, [the district]
was not going to accommodate [her].”
After the hearing, the ULJ issued its second findings of fact and decision, this time
in favor of the district. The ULJ determined that “Brown quit in part because she did not
like the way [the superintendent] treated her, and felt he put roadblocks up making it
difficult for her to perform her job.” It also determined that it was not medically necessary
for Brown to quit when she did because she had been working under the same restrictions
since the beginning of the year.
Brown filed a request for reconsideration of the ULJ’s decision that she was
ineligible for unemployment benefits. In support of her request, Brown submitted
additional documentation responding to the ULJ’s decision. The ULJ denied
reconsideration and affirmed the decision, concluding that it was “factually and legally
correct.” The ULJ further determined that “[t]he new information [Brown] submitted
would not change the outcome of the decision and would not show that information
submitted at the [prior] hearing was false.” Brown appeals.

9
DECISION
Brown challenges the ULJ’s determination that she is ineligible for unemployment
benefits. When reviewing the ULJ’s decision, we may affirm the decision, remand for
further proceedings, or reverse or modify the decision if the relator’s substantial rights were
prejudiced because the decision, among other things, was affected by an error of law or
unsupported by substantial evidence in the record. Minn. Stat. § 268.105, subd. 7(d)
(2024).
Brown raises two arguments on appeal. She first contends that she qualifies for the
serious-illness statutory exception because she had a “serious illness that made it medically
necessary” for her to quit her employment. See Minn. Stat. § 268.095, subd. 1(7) (2024).4
I. The ULJ erred by determining that Brown was not eligible for unemployment
benefits based on the serious-illness statutory exception.

Minnesota’s unemployment insurance program is meant to assist those who become
“unemployed through no fault of their own.” Minn. Stat. § 268.03, subd. 1 (2024). The
statute is “remedial in nature and must be applied in favor of awarding unemployment
benefits.” Minn. Stat. § 268.031, subd. 2 (2024). “[A]ny statutory provision that would
preclude an applicant from receiving benefits must be narrowly construed.” Id.
“In unemployment benefits cases, we review the ULJ’s findings of fact in the light
most favorable to the decision and will not disturb those findings as long as there is

4 Alternatively, Brown argues that she qualifies for the good-reason exception because she
quit for a good reason caused by her employer. See Minn. Stat. § 268.095, subd. 1(1)
(2024). Because we conclude that Brown qualifies for unemployment benefits under the
serious-illness exception, we need not address her alternative argument that she is eligible
under the good-reason exception.

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evidence in the record that reasonably tends to sustain them.” Wilson v. Mortg. Res. Ctr.,
Inc., 888 N.W.2d 452, 460 (Minn. 2016) (quotations omitted). “We defer to the ULJ when
reviewing credibility and conflicting evidence.” Lamah v. Doherty Emp. Grp., Inc., 737
N.W.2d 595, 598 (Minn. App. 2007). We may reverse or modify the ULJ’s decision if it
was unsupported by substantial evidence in view of the entire record or affected by an error
of law, thereby prejudicing the applicant’s substantial rights. Minn. Stat. § 268.105,
subd. 7(d)(4), (5) (2024). Whether the ULJ’s factual findings establish that the applicant
meets a statutory exception to ineligibility for quitting employment is a question of law,
which we review de novo. Peppi v. Phyllis Wheatley Cmty. Ctr., 614 N.W.2d 750, 752
(Minn. App. 2000).
An applicant who quits employment is ineligible to receive unemployment benefits
unless an exception applies. Lamah, 737 N.W.2d at 598. One of these exceptions is when
the applicant quit because of a “serious illness or injury [that] made it medically necessary.”
Minn. Stat. § 268.095, subd. 1(7). This exception “applies if the applicant informs the
employer of the medical problem and requests accommodation and no reasonable
accommodation is made available.” Id. Thus, to qualify for unemployment benefits under
the serious-illness exception, Brown needed to show three elements: (1) that a serious
illness or injury made it medically necessary for her to quit, (2) that she informed her
employer of the illness or injury and requested accommodation, and (3) that no reasonable
accommodation was made. See id.
The parties do not dispute that Brown had a serious illness. The remaining
questions, then, are whether it was medically necessary for Brown to quit, whether Brown

11
informed her employer of the illness and requested an accommodation, and whether the
district made a reasonable accommodation. We address each in turn.
A. The ULJ’s finding that it was not medically necessary for Brown to quit
is unsupported by substantial evidence.

Brown argues that there is no substantial evidence in the record to support the ULJ’s
finding that it was not medically necessary for Brown to quit. We agree.
The statute provides that an appli cant who quits employment may still be eligible to
receive unemployment benefits if “the applicant’s serious illness or injury made it
medically necessary that the applicant quit.” Minn. Stat. § 268.095, subd. 1(7)(i). On
review of a ULJ’s decision, we defer to the ULJ’s credibility determinations and uphold
the ULJ’s findings of fact if supported by substantial evidence. Minn. Stat. § 268.105,
subd. 7(d)(5); Wilson, 888 N.W.2d at 460. Substantial evidence is relevant evidence that
“a reasonable mind might accept as adequate to support a conclusion, or more than a
scintilla of evidence.” Moore Assocs., LLC v. Comm’r of Econ. Sec., 545 N.W.2d 389, 392
(Minn. App. 1996).
The ULJ concluded that it was not medically necessary for Brown to quit “when she
did” because she had been working under the same restrictions since the beginning of the
year. That conclusion is not supported by the record. Brown testified she had serious
trouble maintaining the current work schedule with her medical condition, including
insomnia and concentration difficulties that made classroom management difficult, and
that continuing to work without the requested accommodation was detrimental to her health
and well-being. Brown’s physician opined that, based on Brown’s worsening medical

12
conditions, she was only capable of performing her essential job functions by working a
limited schedule of four hours per day, five days per week. The ULJ made no credibility
findings regarding Brown’s testimony about her medical condition, nor did the ULJ make
any credibility findings concerning the opinions or testimony of Brown’s treating
physician. Although this court generally defers to the ULJ’s credibility determinations, no
such findings were made here. The ULJ did not identify which testimony was credited or
explain how the conflicting evidence was reconciled. As a result, it is difficult to discern
the factual basis for the ULJ’s conclusion and to determine whether that conclusion is
supported by substantial evidence in the record. Furthermore, the record is uncontradicted
that the district never implemented Brown’s work restriction. The district’s HR manager
acknowledged the restriction of four hours per day, five days per week was not
accommodated.
Consequently, we conclude that the ULJ’s finding—that it was not medically
necessary for Brown to quit—is unsupported by substantial evidence.
B. The ULJ’s finding that Brown did not inform her employer that her
medical condition was worsening is unsupported by substantial
evidence.

The ULJ’s finding that Brown failed to inform the district that her medical condition
had worsened is not supported by substantial evidence in the record. The undisputed
evidence shows that, over the course of more than two years, Brown repeatedly notified
the district of her medical conditions, submitted updated physician documentation
reflecting her changing limitations, and requested accommodations that corresponded to
those limitations. In fact, she did so on at least three occasions. Brown first informed the

13
district of her medical condition in August 2021 when she provided a physician’s letter
documenting that she was immuno-compromised. The letter explained that, although
Brown was vaccinated, further exposure could result in “serious long-term effects
including death.” Her physician thus recommended an accommodation that “greatly
reduc[ed] or at best, eliminat[ed] her in person contact with students and staff.” Because
the district did not require students to wear masks, Brown requested that students enrolled
in her classes wear masks in her classroom. Brown also requested that students in her class
follow social-distancing protocols from herself and each other. She alternatively requested
to work remotely. The district denied these requests.
Brown next informed the district of her medical condition in July 2023. She
provided the district with a physician’s letter, indicating that her conditions had worsened.
Her physician stated that Brown was capable of performing her essential functions so long
as her hours were limited to four hours per day, five days per week, with one of those hours
serving as class preparation time. After the district denied this accommodation, Brown
offered an alternative accommodation by “job sharing” with another art teacher at the
school. But the district denied this as well because, by that point, the other teacher had
already accepted a full -time position, even though Brown requested the job share three
months earlier in May 2023.
Brown informed the district of her medical condition for a third time in December
2023. She provided another physician’s letter, stating that she suffered “long COVID,
chronic insomnia, colitis, and generalized osteoarthritis,” as well as “depression and
anxiety.” Her physician reiterated that these conditions had worsened but that Brown could

14
manage her responsibilities if her workday were limited to four hours of class time and one
hour of class preparation time.
To persuade us otherwise, DEED argues that Brown did not inform the district “that
her condition had changed, and that she required a new accommodation.” It claims that
“the [district] was under the reasonable presumption that it had satisfactorily
accommodated Brown’s medical condition.” We are not persuaded.
First, the statute does not require Brown to inform her employer that her medical
condition has changed or to request a new accommodation. All that was required of her
was to inform the district of her medical condition and request an accommodation. And
she did so here. Second, based on the three letters sent by Brown’s physician, coupled with
Brown’s own correspondence to the superintendent, the district knew, or should have
known, that Brown could not maintain the six-hours-per- day schedule. The fact that she
continued working under the district’s accommodation is not dispositive.
On this record, substantial evidence does not support the ULJ’s finding that Brown
failed to inform the district that her medical condition had worsened or that she required
additional accommodations. The undisputed evidence establishes that Brown (1) informed
her employer of her medical illness and its evolving limitations through updated physician
letters and her own communications with the district, and (2) requested accommodations
in the form of reduced working hours or, alternatively, a job-share arrangement.

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C. The ULJ’s reasonable accommodation findings are unsupported by
substantial evidence.

Turning to the third requirement, Brown needed to show that the district made no
reasonable accommodation. See Minn. Stat. § 268.095, subd. 1(7). What constitutes a
reasonable accommodation is a question of statutory interpretation that we review de novo.
Wilson, 888 N.W.2d at 458. “The goal of all statutory interpretation is to ascertain and
effectuate the intent of the legislature.” State by Smart Growth Minneapolis v. City of
Minneapolis, 954 N.W.2d 584, 590 (Minn. 2021) (quotation omitted). “The first step of
statutory interpretation is to determine whether the statute’s language, on its face, is
ambiguous.” Aldean v. City of Woodbury, 2 N.W.3d 918, 921-22 (Minn. App. 2024)
(quotation omitted).
“Reasonable accommodation” is not defined in the statute. See Minn. Stat.
§ 268.095 (2024). When words and phrases are not defined by statute, “we may look to
dictionary definitions to determine a term’s plain and ordinary meaning.” State v. Powers,
962 N.W.2d 853, 858 (Minn. 2021) (quotation omitted). “[R]easonable accommodation”
may be defined as “[a]n adaptation, adjustment, or allowance made for a disabled person’s
needs or an employee’s religious beliefs or practices without imposing an undue hardship
on the party taking the action.” Black’s Law Dictionary 20 (12th ed. 2024). An
“accommodation” is defined as “[t]he act of accommodating or the state of being
accommodated; adjustment. . . . Something that meets a need; a convenience.” The
American Heritage Dictionary of the English Language 11 (5th ed. 2018).

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These definitions suggest that a reasonable accommodation must, at the very least,
effectively address the individual’s needs. This reading is consistent with how “reasonable
accommodation” is defined in the Minnesota Human Rights Act (MHRA). See Minn. Stat.
§ 363A.08, subd. 6 (2024); Gonzalez Diaz v. Three Rivers Cmty. Action, Inc., 917 N.W.2d
813, 818 (Minn. App. 2018) (stating that “addressing accommodation requests in other
areas of law is also instructive” when addressing accommodation requirements in the
unemployment benefits context).
Under the MHRA, “‘[r]easonable accommodation’ means steps which must be
taken to accommodate the known physical or mental limitations of a qualified individual
with a disability.” Minn. Stat. § 363A.08, subd. 6(a). A reasonable accommodation may
include, but is not limited to, “making facilities readily accessible to and usable by
individuals with disabilities,” restructuring jobs, modifying work scheduling, or
reassigning an employee to a vacant position. Id. The employer is generally required to
provide reasonable accommodations to qualified employees unless doing so would impose
an undue hardship.
5 Id.
With these principles in mind, we address whether the district made a reasonable
accommodation available. Brown argues that the district did not make a reasonable
accommodation available because it refused to provide a more workable schedule, despite

5 In determining whether an accommodation would impose an undue hardship, we consider
the nature and cost of the accommodation, the feasibility of financing the accommodation,
the size of the business and the number of employees, the type of operation of the business,
and whether good faith efforts were made to explore less-restrictive or expensive means.
Id., subd. 6(b).

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her physician’s repeated recommendation that she work fewer hours. As a result, her only
option was to resign or continue working to the detriment of her health and well-being.
DEED contends that the district made reasonable accommodations “by providing
work within Brown’s restrictions.” This characterization of the facts is not supported by
the record. The restrictions, based on her physician’s letter, were that she “may work up
to 4 hours 5 days a week.” But the district required her to work six hours per day, five days
per week. The physician wrote to the district again in December 2023, stating that her
chronic issues had worsened and recommended that her workday be limited to a four-hour
schedule. He added, “I do feel that she can manage her teaching responsibilities if these
restrictions are met.”
DEED also argues that the ULJ properly determined that it was not medically
necessary for Brown to quit when she did because she initiated the separation agreement
and because she did not provide the district with adequate time to respond to her
accommodation request. We are not convinced.
Regardless of who initiated the settlement negotiations, Brown could have, at any
time, walked away from negotiations or rejected the terms of the agreement and continued
with her employment. In fact, the district’s HR manager testified that, had Brown not
resigned, “[s]he would have continued employment with the District indefinitely.” The
HR manager added that Brown was a tenured teacher, and there were no disciplinary
proceedings in place at the time. Importantly, Brown continued working through the
following semester until she resigned in March 2024. Thus, the district had sufficient time
to consider and respond to Brown’s renewed accommodation request.

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To convince us otherwise, DEED argues that, by returning to work for the 2023-
2024 school year, Brown impliedly demonstrated that she accepted the accommodation
offered by the district. The record evidence undermines this assertion. At the hearing, the
ULJ asked Brown, “Would you say that by returning to school for the fall that you were
accepting the accommodation that the school was offering?” Brown replied, “No. . . . I
spoke to [the superintendent] and told him that I was not accepting
their . . . accommodations as they were, but I mean, I was going to work, though I did not
agree with it.” However, Brown returned to work only because she felt “[she] had no
choice.” This exchange directly contradicts the ULJ’s finding that she accepted the
accommodations by returning to work. Thus, the ULJ’s finding is not supported by
substantial evidence.
In sum, the ULJ’s conclusion that Brown is ineligible to receive unemployment
benefits under the serious-illness exception is unsupported by substantial evidence in the
record. Brown informed the district of her serious illness, requested accommodations on
numerous occasions with supporting documentation from her physician, and offered a less-
restrictive accommodation by finding another art teacher with whom she could share
classes. And despite informing the district that she continued to struggle under the six-
hours-per-day accommodation, the district made no other reasonable accommodation
available. Brown, therefore, falls within the serious-illness exception and is entitled to
unemployment benefits.
Reversed.