This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case arose from a workers' compensation dispute. The employer's insurer, Rockwood Insurance Company, issued a workers' compensation policy to the employer, New Mexico Drilling and Exploration, Inc., for the period of April 25, 1985, to April 25, 1986. Due to nonpayment of premiums, Rockwood sent a notice of cancellation to the employer on January 28, 1986, effective February 10, 1986. The worker was injured on March 10, 1986. The worker argued that the cancellation was ineffective because Rockwood failed to notify certain third parties, including the Superintendent of Insurance and the certificate holder.
Procedural History
- Trial court: Held that Rockwood Insurance Company failed to effectively cancel its policy and was liable for total disability benefits awarded to the worker.
Parties' Submissions
- Appellant (Rockwood Insurance Company): Argued that it complied with statutory requirements for cancellation by providing written notice to the employer and that no additional notice to third parties, such as the Superintendent of Insurance or the certificate holder, was required under the law in effect at the time.
- Respondent (Worker): Contended that the cancellation was ineffective because Rockwood failed to notify the certificate holder and the Superintendent of Insurance, and argued that public policy under the Workers' Compensation Act supported holding Rockwood liable.
Legal Issues
- Was Rockwood Insurance Company's cancellation of the workers' compensation policy effective under the applicable statutory requirements?
- Did Rockwood have a legal obligation to notify third parties, such as the Superintendent of Insurance or the certificate holder, to effectuate the cancellation of the policy?
Disposition
- The Court of Appeals reversed the trial court's judgment, holding that Rockwood Insurance Company effectively canceled the policy and was not liable for the worker's compensation benefits.
Reasons
Per Chavez J. (Donnelly and Hartz JJ. concurring):
The Court found that Rockwood complied with the statutory requirements for cancellation by providing written notice to the employer at least ten days before the effective date of cancellation, as required by NMSA 1978, Section 59A-18-29(A). The Court rejected the worker's argument that Rockwood was required to notify the certificate holder or the Superintendent of Insurance, noting that no statutory provision in effect at the time imposed such a requirement. The Court also dismissed the worker's reliance on public policy arguments, emphasizing that liberal construction of the Workers' Compensation Act does not permit the court to impose additional obligations not specified by the legislature. Finally, the Court determined that the cancellation was effective and relieved Rockwood of liability for the worker's compensation benefits.