Minnesota Statutes
Minn. Stat. § 181.935 (2026)
Individual Remedies; Penalty
✓ current as of May 2026
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(a) In addition to any remedies otherwise provided by law, an employee injured by a violation of section 181.932 may bring a civil action to recover any and all damages recoverable at law, together with costs and disbursements, including reasonable attorney's fees, and may receive such injunctive and other equitable relief as determined by the court.
(b) An employer who failed to notify, as required under section 181.933 or 181.934, an employee injured by a violation of section 181.932 is subject to a civil penalty of $25 per day per injured employee not to exceed $750 per injured employee.
(c) If the district court determines that a violation of section 181.932 occurred, the court may order any appropriate relief, including but not limited to reinstatement, back pay, restoration of lost service credit, if appropriate, compensatory damages, and the expungement of any adverse records of an employee who was the subject of the alleged acts of misconduct.
Notes of Decisions
Cited in 24
cases (3 in the last 5 years), 1990–2024 · leading case: Abraham v. Cnty. of Hennepin, 639 N.W.2d 342 (Minn. 2002).
Abraham v. Cnty. of Hennepin, 639 N.W.2d 342 (Minn. 2002). “The district court concluded that appellants could pursue claims only under MO-SHA because the specific provisions of MOSHA prevail over the more general provisions of the Whistleblower Act.”
Piekarski v. Home Owners Sav. Bank, F.S.B., 755 F. Supp. 859 (D. Minnesota 1991). “935 be mandatory, it would have used similarly commanding language.”
Williams v. St. Paul Ramsey Med. Ctr., Inc., 551 N.W.2d 483 (Minn. 1996). “Minn.Stat. § 181.935(a) (1994). The majority of the court of appeals noted that, to the extent the Whistleblower Act is applicable to persons alleging discrimination under the Human Rights Act, the remedy provision of the former conflicts with the exclusive remedy provision of…”
Brown v. Diversified Distrib. Sys., LLC, 801 F.3d 901 (8th Cir. 2015). “1995) (citing Minn. Stat. § 181.935 ). Since Brown never alleged a "whistleblower retaliation claim" under § 181.”
Moore v. City of New Brighton, 932 N.W.2d 317 (Minn. Ct. App. 2019). “" Minn. Stat. § 181.935 (a) (2018) (emphasis added).”
Larson v. New Richland Care Ctr., 538 N.W.2d 915 (Minn. Ct. App. 1995). “Minn.Stat. § 181.935(a) (1990). The statutory language contemplates that a municipal employee has the right to bring a whistle-blower action in district court without involving certiorari review.”
Morrow v. Air Methods, Inc., 884 F. Supp. 1353 (D. Minnesota 1995). “Minn.Stat. § 181.935(a). Despite the breadth of § 181.”
McGrath v. TCF Bank Sav., FSB, 502 N.W.2d 801 (Minn. Ct. App. 1993). “Given the manager’s personal experience with McGrath’s complaints, the trial court correctly determined the only conclusion possible from the evidence was that the managers had reasonable and probable cause for their statements about McGrath.”
Luisa Chavez-Lavagnino v. Motivation Educ. Training, 767 F.3d 744 (8th Cir. 2014). “The Whistleblower Act authorizes an award of reasonable attorney’s fees, Minn. Stat. § 181.935 (a), and we review the district court’s decision regarding what constitutes a reasonable fee for abuse of discretion.”
Zirkle v. Dist. of Columbia, 830 A.2d 1250 (D.C. 2003). “On the contrary, and by way of example, Minnesota’s WPA also provides for injunctive relief as a potential remedy, see Minn.Stat. § 181.935(a) (2002), yet the four-part test of Virginia Petroleum Jobbers is nonetheless applied to motions for preliminary injunctive relief brought…”
Dahlberg v. Lutheran Soc. Serv. Of Nd, 2001 ND 73 (N.D. 2001). “Under Minn.Stat. § 181.935, an employee injured by a violation of Minn.”
Manteuffel v. City of North St. Paul, 538 N.W.2d 727 (Minn. Ct. App. 1995). “Minn.Stat. § 181.935(a). The Act applies specifically to governmental employers: ‘Employer’ means any person having one or more employees in Minnesota and includes the state and any political subdivision of the state.”
— Minn. Stat. § 181.935(a) — 14 cases
Abraham v. Cnty. of Hennepin, 639 N.W.2d 342 (Minn. 2002). “The district court concluded that appellants could pursue claims only under MO-SHA because the specific provisions of MOSHA prevail over the more general provisions of the Whistleblower Act.”
Piekarski v. Home Owners Sav. Bank, F.S.B., 755 F. Supp. 859 (D. Minnesota 1991). “935 be mandatory, it would have used similarly commanding language.”
Williams v. St. Paul Ramsey Med. Ctr., Inc., 551 N.W.2d 483 (Minn. 1996). “Minn.Stat. § 181.935(a) (1994). The majority of the court of appeals noted that, to the extent the Whistleblower Act is applicable to persons alleging discrimination under the Human Rights Act, the remedy provision of the former conflicts with the exclusive remedy provision of…”
Larson v. New Richland Care Ctr., 538 N.W.2d 915 (Minn. Ct. App. 1995). “Minn.Stat. § 181.935(a) (1990). The statutory language contemplates that a municipal employee has the right to bring a whistle-blower action in district court without involving certiorari review.”
Morrow v. Air Methods, Inc., 884 F. Supp. 1353 (D. Minnesota 1995). “Minn.Stat. § 181.935(a). Despite the breadth of § 181.”
— Minn. Stat. § 181.935(b) — 1 case
Elliott v. JBM Patrol & Prot. (D. Minnesota 2022).
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