Thornton v. Mott Roofing & Sheet Metal

Citations: 787 P.2d 877; 1989 OK CIV APP 79; 1989 Okla. Civ. App. LEXIS 75; 1989 WL 197823Docket: No. 72266

Court: Court of Civil Appeals of Oklahoma; November 27, 1989; Oklahoma; State Appellate Court

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The Court addressed two critical legal questions regarding jurisdiction and settlement under the Workers’ Compensation Act. First, it determined that the Workers’ Compensation Court does obtain jurisdiction when a claimant submits a Form 3 on the hearing day, even if the form lacks a file stamp until after the Court's order is issued. Second, the Court concluded that the Workers’ Compensation Act does not permit the settlement of a worker's claim through an 'Agreed denial.'

The case involved a petitioner who suffered a heart attack while working on July 27, 1988, during hot weather. Initially misdiagnosed with heat stroke, he was later hospitalized and treated for acute anterior wall myocardial infarction, revealing severe coronary artery disease not caused by his work conditions. Although his heart attack's timing might have been influenced by the heat, his underlying condition was not work-related. Following treatment, his heart function normalized, and he was expected to return to work pending a follow-up.

On September 14, 1988, the petitioner signed a Form 3 for an accidental injury claim, but the trial judge ruled that no injury occurred in the course of employment, a decision co-signed by the petitioner and the respondent's attorney. Notably, while the Form 3 was submitted to the Court Reporter, it was not officially filed for over two months. The record indicates that the trial judge and petitioner had unrecorded discussions, and there was confusion regarding the transcript of the examination conducted by the respondent's counsel, which was not available for review until October 1989. Consequently, the Court could not confirm the evidence considered in the judge's decision. 

After seeking legal counsel, the petitioner attempted to appeal the September 14 order but learned that no official court file existed for his case due to the Form 3 not being filed, leading to the appeal being returned.

Key dates and actions in the case include: the injury occurred on June 27, 1987; an Employer’s notice of injury (Form 2) was filed on July 8, 1987, which assigned Workers’ Compensation Court Number 88-18678Q; an 'agreed denial' was entered on September 14, 1987, with the claimant receiving $46,000; subsequent filings occurred throughout 1988, including various letters and a trial judge's order regarding a different case (Court Number 88-18649-R). The Workers’ Compensation Court established jurisdiction based on the Form 2 submission, supported by Bennett v. Scrivner, 694 P.2d 932 (Okl.1985), indicating that absence of fraud renders the filing of Form 3 sufficient for jurisdiction. 

Workers’ Compensation is governed by statute, specifically Title 85 O.S. 1986 Supp. 26, which requires a signed and court-approved memorandum for any final agreement between employer and employee regarding injury-related facts and resulting disability. Such agreements are binding unless fraud is present. The Court has the authority to investigate claims, order hearings, and determine compensation awards, which must be filed with the Administrator. Further, according to 85 O.S. 1981. 84, the Court can address petitions from either party for final settlement and, if deemed in the best interest of both, render a final award, after which it loses jurisdiction over related claims.

Claims for compensation under the Workers’ Compensation Act cannot be assigned, released, or commuted except as specified in the Act, specifically citing 85 O.S. 1981. 48. Additionally, any waiver of compensation rights by an employee is invalid according to 85 O.S. 1981. 47. The Act allows for two methods of settling claims aside from a full adversary hearing: a Form 14, which is an agreed statement of facts, and a Joint Petition. The statutes clearly indicate that no other methods of release or settlement are authorized. The court determined that the 'agreed denial' used in this case constituted an invalid waiver of the Petitioner’s rights. The Respondent requested that if the court vacated and remanded the case, the Petitioner be ordered to return any payments made under the 'agreed denial.' The court declined this request, leaving the decision to the trial court, and ultimately vacated the trial court's order and remanded the case for further proceedings, with concurrence from Judges Garrett and MacGuigan.