Rose v. Arkansas State Police

Citations: 16 Ark. App. 96; 697 S.W.2d 927; 1985 Ark. App. LEXIS 2184Docket: CA 85-155

Court: Court of Appeals of Arkansas; October 16, 1985; Arkansas; State Appellate Court

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William Rose, an Arkansas State Trooper, was killed in the line of duty on December 28, 1982. His widow received a total of $65,000 in death benefits from various sources: $50,000 under the Public Safety Officers’ Death Benefits Act, $10,000 under Ark. Stat. Ann. 12-2348, and $5,000 under Ark. Stat. Ann. 42-427. The Public Employee Claims Division, Arkansas Insurance Department, acknowledged the widow's claim for workers' compensation benefits but sought a credit against its liability equivalent to the benefits already received. The Commission reversed a prior decision by an Administrative Law Judge that denied this credit, citing Ark. Stat. Ann. 12-3605(G), which allows for such offsets when benefits arise from state or federal programs for public safety officers.

The widow challenged this ruling, arguing that the Public Safety Officers’ Death Benefits Act superseded Arkansas law under the Supremacy Clause of the U.S. Constitution, specifically pointing to provisions that state benefits are in addition to any other benefits due. The argument also referenced the 10th Amendment, which reserves powers not delegated to the federal government to the states. The constitutionality of offsetting federal benefits with state benefits was supported by the Supreme Court case Richardson v. Belcher, which upheld the reduction of social security benefits based on workers’ compensation, asserting that the original purpose of state workers' compensation laws was to fill gaps not covered by private insurance or tort claims. The Commission's grant of a $65,000 credit against the widow's workers' compensation benefits was ultimately affirmed.

Congress has not clearly indicated an intention to override state authority over workers’ compensation benefits through the Public Safety Officers’ Death Benefits Act, and there is no viable supremacy clause argument. The appellant contends that the Full Commission misinterpreted Act 929 of 1981 by requiring credits for benefits received from the Arkansas Claims Commission and Arkansas State Police against the appellant’s compensation claim. The appellant received $10,000 and $5,000 from these entities following the death of Trooper Rose in the line of duty. 

Workers’ compensation statutes must be interpreted liberally in favor of claimants to support their intended humanitarian purposes; however, the explicit language of Ark. Stat. Ann. 12-3605(G) necessitates that benefits received from any state or federal program be credited against workers’ compensation benefits. This concept is supported by case law from other jurisdictions where similar offsets have been upheld. 

For instance, in Maryland, benefits paid under a city ordinance offset the city’s workers’ compensation obligations, while Rhode Island law allows for federal benefits to offset state compensation unless explicitly stated otherwise. Given the precedent and the General Assembly’s authority to legislate such offsets, it is clear that the Arkansas legislature has enacted Ark. Stat. Ann. 12-3605(G) to manage benefits and prevent “double-dipping.” The court emphasizes that it cannot question the legislature's choices, which are aimed at effective budget management. Any intent to exclude specific cases from this statute must be directly addressed by the legislature. The court finds no error in the Full Commission's decision and affirms the ruling. Cooper and Glaze, JJ., concur. The statute was later amended by Act 839 of 1985 to increase available benefits up to $100,000.