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 claimant, who was the president, CEO, and sole stockholder of his employer corporation, alleged that he sustained a work-related injury. He did not provide written notice of the injury to the employer but argued that his own awareness of the injury constituted actual notice to the corporation under New Mexico law. The employer and insurer disputed the claim, asserting a lack of notice and causation for the alleged disability (paras 1-2).
Procedural History
- Workers' Compensation Administration: The Workers' Compensation Judge (WCJ) ruled that the employer did not have actual notice of the injury and that the claimant's disability was not caused by the alleged work-related accident (para 1).
Parties' Submissions
- Claimant-Appellant: Argued that as the sole officer of the corporation, his knowledge of the injury constituted actual notice to the employer under Section 52-1-29(B). He also contended that the uncontradicted medical evidence established causation between the accident and his disability (paras 1-2, 10-11).
- Respondents-Appellees (Employer and Insurer): Asserted that the claimant failed to provide the required notice and that his actions raised suspicions of fraud. They also argued that the WCJ was correct in finding no causation and that the claimant's disability was preexisting and unrelated to the alleged accident (paras 8-9, 12).
Legal Issues
- Whether the claimant's awareness of his own injury constituted actual notice to the employer under Section 52-1-29(B) (para 2).
- Whether the claimant's disability was caused by the alleged work-related accident (para 10).
Disposition
- The Court of Appeals reversed the WCJ's decision on both the notice and causation issues and remanded the case for further proceedings (paras 2, 13-14).
Reasons
Per Chavez J. (Donnelly and Minzner JJ. concurring):
Notice: The Court held that when a worker is the president, CEO, and sole stockholder of the employer corporation, the corporation is deemed to have actual knowledge of the injury under Section 52-1-29(B). The Court rejected the respondents' argument that notice to oneself does not satisfy the statutory requirement, emphasizing that the plain language of the statute must be enforced. The Court noted that the WCJ could still find no accident or causation if fraud or suspicious circumstances were present, but such findings must be based on evidence, not on the absence of notice (paras 2, 5-9).
Causation: The Court found that the WCJ erred in concluding there was no causation. The uncontradicted medical evidence established that the claimant's condition was either caused by the accident or was an aggravation of a preexisting condition caused by the accident. The Court emphasized that the WCJ was bound by the uncontradicted medical evidence rule and remanded the case for further findings on the nature and extent of the claimant's disability (paras 10-12).
Remand: The Court directed the WCJ to determine the amount of medical and other benefits to be awarded, taking into account the claimant's counsel's services on appeal (para 13).