HomeMy WebLinkAboutResolution 9126RESOLUTION NO. 9126
CITY OF MOUNDS VIEW
COUNTY OF RAMSEY
STATE OF MINNESOTA
RESOLUTION APPROVING MEDIATED SETTLEMENT AGREEMENT AND
RELEASE OF CLAIMS
WHEREAS, Keith Demarest was previously employed by the City as a patrol
officer with the Police Department; and
WHEREAS, Mr. Demarest allegedly sustained injuries in the line of duty, which
the City denies; and
WHEREAS, Mr. Demarest was granted Police and Fire Plan duty disability
benefits by the Public Employees Retirement Association (PERA), pursuant to Minn.
Stat. § 353.656, Subd. 1; and
WHEREAS, Mr. Demarest claims to be entitled to continuation of health
insurance coverage under Minn. Stat. § 299A.465, as a result of his duty disability,
which the City denies; and
WHEREAS, the parties participated in mediation on May 29, 2019 and reached a
settlement of Mr. Demarest's claim under Minn. Stat. § 299A.465; and
WHEREAS, the parties wish to resolve their differences without the cost, delay
and uncertainty of litigating the matter; and
WHEREAS, the Settlement Agreement provides for the resolution of the dispute
between the parties as well as a release of all claims for the future payment of any
health insurance premiums by the City on behalf of Mr. Demarest under Minn. Stat. §
299A.465.
NOW, THEREFORE, BE IT RESOLVED THAT the above -referenced recitals are
incorporated herein to this Resolution.
NOW, THEREFORE, BE IT FURTHER RESOLVED, that the City Council hereby
approves the Settlement Agreement in substantially the form as attached hereto as
Exhibit A, the contents of which are incorporated herein by reference.
NOW, THEREFORE, BE IT FURTHER RESOLVED THAT, the Mayor, the City
Administrator and the City Attorney are hereby authorized and directed to take any and
all additional steps and actions necessary or convenient to prepare the appropriate
documents and/or agreements to facilitate the directives of the City Council as provided
herein in order to accomplish the intent of this Resolution.
Resolution 9126
June 10, 2019
Page 2
Adopted this 10th day of June, 2019.
A��ll�
Carol A. Mueller, Mayor
ATTEST:
I
Nyle d<mu d, CiN Administrator
The 148ouncis View Vision
A Thriving Desirable Co mrmadi'v
SETTLEMENT AGREEMENT AND RELEASE OF CLAIMS
This Settlement Agreement and Release of Claims is made by and between
Keith Demarest ("Demarest") and the City of Mounds View ("City").
RECITALS
WHEREAS, Demarest was formally employed by the City as a police officer; and
WHEREAS, Demarest allegedly sustained injuries in the line of duty, which the
City denies; and
WHEREAS, Demarest was granted Police and Fire Plan duty disability benefits
by the Minnesota Public Employees Retirement Association ("PERA"), pursuant to
Minn. Stat. § 353.656, Subd. 1; and
WHEREAS, Demarest claims to be entitled to continuation of health insurance
coverage from the City through age 65 under Minn. Stat. § 299A.465 ("299A Claim"), as
a result of his duty disability, which the City denies; and
WHEREAS, the parties participated in mediation on May 29, 2019 and reached a
settlement of Demarest's 299A Claim; and
WHEREAS, the parties now wish to memorialize the terms of their mediated
settlement in this Agreement.
AGREEMENT
1. Settlement Payment. In full and final settlement and release of Demarest's
299A Claim, the City agrees to pay Demarest the sum of $90,000.00, as
compensation for all claims against the City under Minn. Stat. § 299A.465. The
parties agree that the settlement payment represents a compromise of the City's
monthly insurance obligation to Demarest, which commenced the date of PERA's
in -line -of -duty determination and would expire on when Demarest reaches the
age of 65.
2. Taxes. Demarest is responsible for any tax obligations, state or federal, as a
result of this settlement payment, and he agrees to hold the City harmless as to
any of his tax liabilities.
3. Release of Claims. In consideration for the settlement payment, Demarest
releases the City from any and all claims, causes of action, damages, costs,
attorneys' fees, or liabilities of any nature, known and unknown relative to his
actual and potential rights under Minn. Stat. § 299A.465, including but not limited
to claims existing up to and including the date of this Agreement and Release,
Settlement Agreement - Demarest
June 10, 2019
Page 2
and further agrees not to commence suit based upon any of the foregoing. The
claims released by this Agreement include any and all claims pursuant to Minn.
Stat. § 299A.465, including, but not limited to, claims related to the continuation
of healthcare insurance coverage by the City.
Demarest also releases the City from all liability for any damages, actions, or
claims, arising out of, or relating to, his separation from employment with the
City, to the extent such claims are waivable.
The parties agree that this Release is not intended to waive Demarest's
Minnesota workers' compensation rights, if any, or his PERA Police and Fire
Plan pension rights under Minn. Stat. § 353.656, subd. 1.
4. Consideration. Demarest agrees that the settlement payment is a full and fair
payment and sufficient consideration for the release of claims in this Agreement.
5. No Admission of Liability. This Agreement is not an admission of guilty or
liability by either party.
6. Binding Agreement. The Release of Claims in this Agreement will bind
Demarest and his heirs, executors, administrators, assigns, agents, partners, and
successors in interest. Demarest represents that no right, claim or cause of
action covered by the Release has been assigned or been given to someone
else.
7. Voluntary Agreement. Demarest represents that he (a) has read this
Agreement and Release carefully; (b) understands its provisions; (c) has had an
opportunity to consult with an attorney; (d) has not been influenced to sign this
Agreement by any statement or representation by the City; and (e) enters into
this Agreement and Release of Claims knowingly and voluntarily.
8. Public Data. This Agreement is public data. To the extent allowed by law, all
other personnel data relating to Demarest is private personnel data.
9. Responsibility for Costs. Each party shall be solely responsible for its own
costs, expenses, and attorney fees.
10. Non -precedential. This Agreement is reached based solely on the
circumstances of the present matter and will not set a precedent for the handling
of future grievances or claims related to the same subject matter.
11. Entire Aareement. This Agreement contains the entire understanding between
the parties and supersedes all other agreements and understandings relating to
the subject matter of this Agreement.
Settlement Agreement - Demarest
June 10, 2019
Page 3
12.Amendments. This Agreement may not be amended or terminated unless
agreed to in writing by the parties and approved by the City's governing body.
13.Severability. If any part of this Agreement is construed to be in violation of any
law, the remaining portions shall remain in full force and effect.
14. Governing Law. This Agreement is governed by the laws of Minnesota.
15. Counterparts. This Agreement may be executed in counterparts, each of which
will be deemed an original, but all of which will constitute one and the same
agreement.
IN WITNESS WHEREOF, Demarest and the City have approved and executed
this Agreement on the dates indicated below.
Dated: June 10, 2019 City of Mounds View
Carol A. Mueller, Mayor
ATTEST:
AX lA
Nyle ikmy d, City Administrator
Date: 2019
Keith Demarest