Narrative Opinion Summary
This case involves two appeals concerning workers' compensation claims denied due to lack of timely notice as required by 39 M.R.S.A. § 63. In Norman St. Pierre v. Morin Brick Co., the Supreme Judicial Court of Maine upheld the denial of St. Pierre’s claim because he failed to provide the requisite 30-day notice of his injury. St. Pierre argued that his employer's knowledge of his injury should excuse the notice requirement under 39 M.R.S.A. § 64. The court, however, emphasized the employee's burden to prove such knowledge and deferred to the Commissioner's findings, which were upheld due to a lack of compelling evidence of employer awareness. Similarly, in Murray v. T. W. Dick Co. Inc., the court affirmed the commissioner's conclusion that the employee did not prove the employer's knowledge of the work-related injury, thereby upholding the denial of the claim. Despite the denial of Murray's appeal, the court ordered the employer to pay $550 in attorney fees and expenses. Both cases underscore the stringent enforcement of statutory notice requirements in workers' compensation claims.
Legal Issues Addressed
Attorney Fees and Expenses on Appealsubscribe to see similar legal issues
Application: An employer may be required to cover reasonable attorney fees and expenses incurred by the employee in an appeal process even if the employee's appeal is denied.
Reasoning: Additionally, the employer was ordered to pay the employee $550 in attorney fees and reasonable out-of-pocket expenses for the appeal.
Burden of Proof for Employer's Knowledge under 39 M.R.S.A. § 64subscribe to see similar legal issues
Application: The burden of proof lies with the employee to establish that the employer had knowledge of the work-related nature of the injury to excuse the notice requirement.
Reasoning: St. Pierre acknowledged his failure to give notice but argued that the employer's knowledge of the injury should excuse this requirement under 39 M.R.S.A. § 64.
Deference to Commissioner's Findingssubscribe to see similar legal issues
Application: The court must defer to the Commissioner's findings unless there is a lack of competent evidence supporting those findings.
Reasoning: The court reiterated that it must defer to the Commissioner's findings unless they lack competent evidence.
Inference of Employer Knowledgesubscribe to see similar legal issues
Application: Even if circumstances might allow for an inference of employer knowledge, without compelling evidence, the Commissioner's findings will be upheld.
Reasoning: Although the court recognized that the Commissioner could have inferred the employer's knowledge based on the circumstances, the absence of compelling evidence in the record meant that the Commissioner's findings were valid.
Notice Requirement under 39 M.R.S.A. § 63subscribe to see similar legal issues
Application: The court emphasized the necessity of providing a 30-day notice for injury claims, reinforcing that failure to comply results in denial of compensation.
Reasoning: The Supreme Judicial Court of Maine upheld the Workers' Compensation Commission's denial of St. Pierre's compensation claim due to his failure to provide the required 30-day notice of his back injury sustained on May 29, 1979.