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Highfield's Alignment Service v. Scott
Citations: 624 So. 2d 630; 1993 Ala. Civ. App. LEXIS 183; 1993 WL 114466Docket: AV92000036
Court: Court of Civil Appeals of Alabama; April 16, 1993; Alabama; State Appellate Court
In this workers’ compensation case, the trial court determined that Highfield’s Alignment Service, the employer, intentionally interfered with the employee's medical bill payments. As a result, the employee is entitled to recover double workers’ compensation benefits under Section 25-5-8(e) of the Code 1975, which imposes penalties for failing to secure compensation payments. This section also establishes that employers failing to secure compensation face misdemeanor charges and potential fines ranging from $25 to $1,000. The court found that the employee had not been able to work since October 23, 1990, and had been receiving compensation, including 49 weeks of temporary total benefits and ongoing payments of $47.13 per week due to a 28% reduction in earning capacity. The court noted that all medical expenses had not been paid by the employer, and Almon J. Highfield, acting as the employer's owner, misrepresented the employee’s coverage status to a collection agency and a hospital, claiming the employee was responsible for the bills and that the workers’ compensation case was settled. These misrepresentations were deemed erroneous and constituted intentional interference with the employee's medical claims under workers’ compensation law. The court referenced precedents indicating that an employer's failure to pay legitimate medical claims or interference in payment should result in the doubling of the compensation amount due. The ruling emphasizes that the statutory intent is to ensure fair payment of valid workers’ compensation claims, and to not penalize interference with medical payments would undermine the statute’s purpose. The employer's appeal centers on the trial court's decision to award double workmen’s compensation benefits under 25-5-8(e), Code 1975, alleging the employer denied responsibility for medical expenses. The Alabama Supreme Court has clarified that the standard of review from Ex parte Eastwood Foods, Inc. applies only to factual findings, not legal conclusions. In Ex parte Cash, the court determined the trial court misapplied the law, leading to a reversal of its judgment. It is acknowledged that the employer had valid workers’ compensation coverage and that benefits had already been paid to the employee as ordered. Additionally, the court indicated that if an employer acts in bad faith regarding medical payments, the trial court may award attorney fees to the prevailing party in civil contempt cases, referencing Argo Constr. Co. v. Rich. The trial court confirmed that all medical expenses have now been settled by the employer. Consequently, the judgment awarding double benefits has been reversed. The decision was concurred by Judges THIGPEN and YATES.