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

The Worker was injured in July 1990 while working on an oil rig operated by the Employer. At the time, the Worker was an hourly employee paid by a payroll company, D & D Employment Agency, which worked exclusively for the Employer. D & D and its insurance carrier provided workers' compensation benefits to the Worker until March 1992, when the Worker and D & D entered into a lump sum settlement agreement releasing D & D and its carrier from liability for future compensation and medical care (paras 1-2).

Procedural History

• Workers' Compensation Administration, March 1992: Approved the settlement agreement between the Worker and D & D, releasing D & D from liability for future compensation and medical care (para 1).
• Workers' Compensation Administration, July 1992: Denied the Worker's attempt to reopen the settlement agreement with D & D and granted summary judgment in favor of D & D (para 2).

Parties' Submissions

• Worker-Appellant: Argued that a worker may have multiple employers for workers' compensation purposes and that the Employer, Aztec Well Servicing Co., was also liable for medical expenses. The Worker contended that the settlement with D & D did not preclude claims against the Employer and sought discovery to determine the relationship between D & D and the Employer (paras 4, 8, 12).
• Employer-Appellee: Asserted that the Worker's claim was barred by the doctrines of res judicata, collateral estoppel, and judicial estoppel due to the prior settlement with D & D. The Employer also argued that the settlement agreement fully satisfied any claims related to the Worker's injury (paras 5-7, 9, 11-12).

Legal Issues

• Can a worker have multiple employers liable for workers' compensation benefits under the circumstances of this case?
• Does the doctrine of res judicata bar the Worker's claim against the Employer?
• Does the doctrine of collateral estoppel preclude the Worker from litigating the issue of the Employer's liability?
• Does the doctrine of judicial estoppel prevent the Worker from asserting that the Employer was also an employer?
• Did the settlement agreement with D & D release the Employer from liability?

Disposition

• The Court of Appeals reversed the summary judgment granted to the Employer and remanded the case for further proceedings (para 14).

Reasons

Per Pickard J. (Minzner CJ. and Hartz J. concurring):

• The Court agreed with the Worker that a worker may have multiple employers for workers' compensation purposes if certain conditions are met, such as the special employer having the right to control the work and the work being essentially that of the special employer (para 4).
• On the issue of res judicata, the Court found that the privity element was not established between D & D and the Employer. The Worker should have been allowed to conduct discovery to determine the relationship between D & D and the Employer before summary judgment was granted (paras 6-8).
• Regarding collateral estoppel, the Court held that the issue of whether the Employer was an employer had not been litigated in the prior case, and thus collateral estoppel did not apply (para 10).
• The Court rejected the Employer's argument of judicial estoppel, noting that the Worker's prior position that D & D was an employer was not inconsistent with the current claim that the Employer was also an employer (para 11).
• The Court concluded that the settlement agreement with D & D did not release the Employer from liability, as the agreement only named D & D and its carrier and did not indicate an intent to release other parties (para 12).