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, a certified public accountant, was hired by the Respondent company in 1981 as a bookkeeper under an agreement labeling her as "contract labor." She worked on various financial tasks for the company, using its premises and equipment. On May 13, 1981, she fell and broke her hip while working. The Respondent's insurer initially covered her medical expenses and temporary disability benefits. In 1984, the Claimant changed her status to "employee" to access company benefits. In 1987, she developed complications from the 1981 injury, underwent surgery, and was later terminated in 1988. She filed a workers' compensation claim in 1989 (paras 2-7).
Procedural History
- Workers' Compensation Administration: The workers' compensation judge dismissed the Claimant's claim, finding that she was not an employee at the time of her injury and that her claim for disability benefits was barred by the statute of limitations.
Parties' Submissions
- Claimant-Appellant: Argued that the statute of limitations should have been tolled due to representations by a Workers' Compensation Division employee and that she was an employee, not an independent contractor, at the time of her injury. She also contended that the Respondents were estopped from denying her employee status and that she was entitled to medical and disability benefits (paras 1, 7, 19, 28-30).
- Respondents-Appellees: Asserted that the Claimant was an independent contractor at the time of her injury, the statute of limitations barred her claim for disability benefits, and they were not estopped from denying her employee status. They also argued that the Claimant was not entitled to medical benefits (paras 1, 8, 22).
Legal Issues
- Was the Claimant's claim for disability benefits barred by the statute of limitations?
- Did the statute of limitations toll due to representations by a Workers' Compensation Division employee?
- Was the Claimant an employee or an independent contractor at the time of her injury?
- Were the Respondents estopped from denying the Claimant's employee status?
- Was the Claimant entitled to medical benefits under the Workers' Compensation Act?
Disposition
- The denial of disability benefits was affirmed as the claim was barred by the statute of limitations (para 20).
- The denial of medical benefits was reversed, and the case was remanded for further findings on the Claimant's employment status at the time of her injury (para 33).
Reasons
Per Hartz J. (Apodaca and Chavez JJ. concurring):
Statute of Limitations: The court held that the statute of limitations began in July 1981 when the Claimant returned to work on crutches and knew or should have known of her disability. The one-year tolling period for continued employment expired long before the claim was filed in 1989. Representations by a Workers' Compensation Division employee in 1987 could not revive a time-barred claim (paras 9-19).
Employment Status: The court found that the workers' compensation judge (WCJ) focused on the "control test" to determine the Claimant's status as an independent contractor. However, the court emphasized that for professionals like accountants, the "relative nature of the work" test is more appropriate. The Claimant's full-time, exclusive services to the company and her regular salary suggested an employee relationship. The case was remanded for further findings on her employment status at the time of the injury (paras 22-27).
Estoppel: The court rejected the Claimant's estoppel arguments. The prior unemployment compensation decision did not establish her employment status in 1981, and there was no evidence of detrimental reliance on the Respondents' conduct to support estoppel (paras 28-31).
Medical Benefits: The court clarified that there is no statute of limitations for medical benefits under the Workers' Compensation Act. The denial of medical benefits was reversed, pending further findings on the Claimant's employment status (paras 21, 33).