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 was injured while employed by Blake's Lotaburger. The worker, the employer, and the employer's insurer entered into a settlement agreement that included a $50,000 lump-sum payment, continuing medical benefits, and attorney fees. The worker sought approval of the lump-sum payment, citing personal financial needs, including paying off debts, vocational retraining, and medical expenses for her husband. The Workers’ Compensation Judge (WCJ) denied the lump-sum payment, citing statutory restrictions under the Workers’ Compensation Act (paras 2-4, 6, 8).
Procedural History
- Workers’ Compensation Administration, Victor Lopez, Workers’ Compensation Judge: Denied approval of the initial lump-sum settlement agreement and later approved a partial lump-sum payment for accrued debts and a subsequent compensation order with periodic payments (paras 3-4, 6).
Parties' Submissions
- Appellant (Worker): Argued that the WCJ erred in denying the lump-sum settlement agreement, claiming it was fair, equitable, and in her best interest. She contended that the WCJ misinterpreted the Workers’ Compensation Act and that the Act’s restrictions on lump-sum payments violated her constitutional rights, including equal protection and the right to acquire and protect benefits (paras 3, 6, 8).
- Appellee (Employer/Insurer): Declined to take a position on the worker’s arguments and did not participate further in the appeal (para 5).
Legal Issues
- Did the WCJ err in denying approval of the lump-sum settlement agreement under the Workers’ Compensation Act?
- Does the Workers’ Compensation Act violate the worker’s constitutional rights, including equal protection and the right to acquire and protect benefits?
Disposition
- The Court of Appeals affirmed the WCJ’s decision to deny the lump-sum settlement agreement (para 8).
Reasons
Per Timothy L. Garcia J. (Michael E. Vigil J. and Cynthia A. Fry C.J. concurring):
The Court held that the WCJ correctly interpreted the Workers’ Compensation Act, which disfavors lump-sum payments except under specific statutory exceptions. The Act prioritizes periodic payments to protect workers’ long-term financial stability. The worker’s proposed settlement did not meet the exceptions outlined in Section 52-5-12(B), (C), or (D) of the Act. Ignoring these statutory requirements would render the provisions meaningless, contrary to principles of statutory interpretation (paras 6-8).
The Court also rejected the worker’s constitutional arguments, as they were not preserved at the lower level. The worker failed to provide evidence that these issues were raised before the WCJ, and the Court declined to address them on appeal (para 9).
Concurring Opinion by Cynthia A. Fry C.J.:
Chief Judge Fry expressed concern that the Court’s interpretation of the Act, based on the Supreme Court’s decision in Sommerville, might be overly restrictive. She noted that the Act’s 2009 amendments allow for broader discretion in approving lump-sum settlements if they are fair, equitable, and in the worker’s best interest. However, given the binding precedent in Sommerville, she agreed with the majority’s decision to affirm the WCJ’s denial of the settlement (paras 10-12).