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 involves a workers' compensation dispute where the claimant sought reimbursement for past medical expenses related to a back injury allegedly caused by a workplace accident. The Workers' Compensation Judge initially denied the claim for past medical expenses but later awarded $6,879.12 after a remand. The employer contested the award, arguing it was entered in error and sought to have the matter reconsidered by the Workers' Compensation Administration (paras 1-3).
Procedural History
- Workers' Compensation Administration, Initial Decision: Denied the claimant's request for past medical expenses related to the back injury (para 3).
- Court of Appeals, Unpublished Memorandum Opinion: Reversed findings that the claimant failed to give notice of the injury and that there was no substantial evidence of a work-related back condition. The court remanded the case for further proceedings but did not address past medical expenses (para 3).
- Workers' Compensation Administration, Amended Judgment: Awarded $6,879.12 in past medical expenses to the claimant (para 12).
Parties' Submissions
- Appellant (Employer): Argued that the award of past medical expenses violated the appellate court's prior mandate, was based on a misrepresentation by the claimant's counsel, and that the amount awarded was excessive and unsupported by the evidence (paras 4-5).
- Respondent (Claimant): Asserted entitlement to the full amount of past medical expenses and maintained that the award was consistent with the appellate court's prior decision (paras 10-11).
Legal Issues
- Whether the Workers' Compensation Administration's award of past medical expenses was entered in error and violated the appellate court's prior mandate.
- Whether the Workers' Compensation Administration had jurisdiction to reconsider its judgment under Section 52-5-9 of the Workers' Compensation Act.
Disposition
- The Court of Appeals granted the employer's motion to remand the case to the Workers' Compensation Administration for reconsideration of the award of past medical expenses (para 21).
Reasons
Per Hartz J. (Donnelly and Bivins JJ. concurring):
The court found that the Workers' Compensation Administration's award of past medical expenses was potentially entered under a mistake or inadvertence, as the judge's oral statements during the hearing suggested a different intent than what was reflected in the written judgment (paras 10-13). The court held that Section 52-5-9 of the Workers' Compensation Act, which allows modification of compensation orders based on mistake or inadvertence, applied to this case despite the claimant's cause of action arising before the statute's effective date. The court reasoned that the statute was intended to govern all proceedings before the Workers' Compensation Administration and that its application here avoided a gap in the law (paras 7-8).
The court emphasized that remanding the case to the Workers' Compensation Administration would facilitate the correction of errors and promote judicial efficiency, particularly when the lower tribunal acknowledged the error and expressed an inclination to correct it (paras 18-20). The court clarified that its decision to remand did not imply any view on the merits of the parties' substantive arguments (para 20).
The motion to remand was granted, allowing the Workers' Compensation Administration to reconsider its judgment (para 21).