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Providence Hospital v. Mabins

Citations: 835 So. 2d 214; 2002 Ala. Civ. App. LEXIS 371; 2002 WL 959745Docket: 2010164

Court: Court of Civil Appeals of Alabama; May 10, 2002; Alabama; State Appellate Court

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Patricia Mabins sustained injuries to her left shoulder, arm, and neck while working at Providence Hospital on June 18, 1999. On May 25, 2000, Mabins and Providence sought court approval for a settlement, which included a $6,000 payment to Mabins and an agreement that Providence would cover all medical expenses related to her injuries for one year. The court approved this settlement. 

On June 14, 2001, Mabins filed a motion to enforce or set aside the settlement, claiming that Providence had not paid for certain spinal treatments she deemed related to her workplace injury. Providence responded, stating it had declined to cover treatments not connected to the injury and that Mabins had failed to file her motion within the required six-month timeframe under Alabama law.

After a hearing, the trial court ruled to enforce the settlement, extending medical benefits for an additional six months based on the recommendations of Mabins's physician. Providence appealed, arguing that the trial court’s order did not comply with Alabama Code § 25-5-88, which requires specific findings of fact and conclusions of law in workers' compensation cases. The appellate court agreed, noting the trial court failed to determine if the cervical injury was related to the original workplace incident. Consequently, the appellate court reversed the trial court's judgment and remanded the case for compliance with the statutory requirements. Judges Crawley, Thompson, and Pittman concurred, while Judge Murdock concurred in the result. Mabins did not submit a brief for the appeal.