AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

A worker employed by Plastech Corporation began experiencing pain and swelling in her wrists in 1991, later diagnosed as carpal tunnel syndrome. Despite worsening symptoms, she continued working until October 1994, when she could no longer perform her duties. She filed a claim for workers' compensation benefits in March 1995, asserting that her condition was work-related (paras 2-4).

Procedural History

• Workers' Compensation Judge: Dismissed the worker's claim, finding it barred by the statute of limitations, as she "knew or should have known" of her compensable injury in 1991 (para 1).
• Court of Appeals: Affirmed the dismissal, concluding substantial evidence supported the finding that the statute of limitations began in 1991 (para 1).

Parties' Submissions

• Worker-Petitioner: Argued that the statute of limitations should not begin until she was entitled to benefits, which she claimed occurred in 1994 when she became unable to work (para 1).
• Employer-Insurer-Respondents: Contended that the worker knew or should have known of her compensable injury in 1991, triggering the statute of limitations, and that no demand for payment was necessary to start the limitations period (paras 1, 6).

Legal Issues

• Does the statute of limitations for workers' compensation claims begin when a worker knows or should know of a compensable injury, or when the worker becomes entitled to benefits?
• Was there substantial evidence to support the finding that the worker's claim was barred by the statute of limitations?

Disposition

• The Supreme Court of New Mexico reversed the dismissal of the worker's claim and remanded the case for further proceedings on the merits (para 1).

Reasons

Per Minzner J. (Franchini C.J. and Baca J. concurring):

• The statute of limitations under the Workers' Compensation Act begins when a worker is entitled to benefits and knows or should know of the injury (paras 11-12). The entitlement to benefits requires a determination of disability or scheduled injury, which the Workers' Compensation Judge (WCJ) did not address (paras 1, 13).
• The WCJ's conclusion that the worker's claim was barred by the statute of limitations lacked substantial evidence. The worker continued performing her pre-injury duties without assistance or reduced pay until 1994, indicating no temporary total disability before that time (paras 16-17).
• The worker did not reach maximum medical improvement until 1995, precluding a finding of permanent partial disability or scheduled injury before that date (paras 21-25).
• The WCJ failed to make necessary findings of ultimate fact regarding the worker's disability status, rendering the conclusion on the statute of limitations unsupported (paras 13, 28).
• The Court remanded the case for a determination of the worker's entitlement to workers' compensation benefits (para 28).