Justia Government & Administrative Law Opinion Summaries

Sonya Chaffee, on behalf of her minor child, Fredrick Latham, Jr., sued the Jackson Public School District; Lonnie J. Edwards, the School District superintendent in his official capacity; and Jackson Public Schools Board of Trustees (collectively, “the School District”) alleging negligence and res ipsa loquitur. Fredrick was a student in Tracy Scott’s first grade class at Woodville Heights Elementary School. While Scott was standing at the front of the classroom readying the students for lunch, Fredrick and another boy got out of line and ran to the back of the classroom to use the single restroom. Bernice Anderson, Scott’s teaching assistant, was present at her desk in the back of the classroom nearer the restroom. Fredrick was injured when his hand slipped off the door and his finger got caught in the crack of the door as the other boy was closing it. After hearing a student scream that Fredrick had smashed his finger, Scott went to the back of the classroom, wrapped Fredrick’s finger in papers towels, and took him to the principal’s office. Fredrick’s mother was called, and he was taken by ambulance to the University of Mississippi Medical Center. Surgery was performed to reattach Fredrick’s fingertip using a skin graft. The School District defended on sovereign immunity grounds pursuant to the Mississippi Tort Claims Act (“MTCA”). After engaging in discovery, the School District moved for summary judgment which was granted. Aggrieved, Chaffee appealed, but finding no reversible error, the Mississippi Supreme Court affirmed. View "Chaffee v. Jackson Public School District" on Justia Law

Miranda Moser dislocated her right shoulder when she lifted a 24-pack of soda while working as a cashier for Rosauers Supermarkets, Inc. (“Rosauers”). Rosauers accepted the claim even though Moser had a pre-existing history of recurrent instability of her right shoulder. Moser underwent shoulder surgery. Afterward, she continued to suffer from “pseudosubluxation” and her surgeon, Dr. Adam Jelenek, recommended she receive a second opinion from a physician in Seattle. Rather than authorizing the request for referral, Rosauers arranged for Moser to be evaluated by Dr. Michael Ludwig who opined that Moser’s shoulder dislocation likely resulted from her pre-existing condition. Dr. Ludwig concluded that Moser had returned to her pre-injury baseline and that she did not require any further medical care. Rosauers filed a notice of medical exam to be performed by Dr. Joseph Lynch on February 5, 2018. Moser responded with a letter conveying she would not be attending the medical exam. Moser filed a Judicial Rule of Practice and Procedure (“J.R.P.”) 15 petition for a declaratory ruling, seeking an order on whether an employer could compel a claimant to attend an Idaho Code section 72-433 examination without first establishing the claimant was within her “period of disability,” which she argued was limited to a period when she was actually receiving benefits. Thereafter, Moser filed a notice that she would not attend the medical examination Rosauers had scheduled for April 2, 2018. The Commission held that following the claim of an accident, injury, or occupational disease, an employer may require a claimant’s attendance at such a medical examination. Moser appeals the Commission’s order. Finding no reversible error in the Commission’s judgment, the Idaho Supreme Court affirmed. View "Moser v. Rosauers" on Justia Law

The Supreme Court affirmed the district court's denial of the City of Reno's petition for judicial review of an appeals officer's decision that the City was not entitled to reduce Respondent's lump sum permanent partial disability (PPD) payment, holding that there is no legal basis to justify a workers' compensation insurer's reduction of the twenty-five-percent lump sum payment limit for an employee's PPD award.An injured employee may elect to receive a lump sum payment for a PPD award, but if the employee's PPD rating exceeds a twenty-five percent whole person impairment (WPI), the employee may only elect to receive a lump sum payment for up to twenty-five percent of the rating. Respondent suffered three industrial injuries. With respect to Respondent's third PPD payment, the City offered Respondent an eighteen-percent lump sum payment, believing it could deduct Respondent's two previous PPD lump sum payments from the twenty-five percent limit. A hearing officer found that the City erred. An appeals officer affirmed and district court affirmed. The Supreme Court affirmed, holding that the appeals officer correctly determined that Respondent was entitled to a lump sum payment for the first twenty-five percent of her most recent WPI rating and PPD award with the remaining eight percent to be paid in installments. View "City of Reno v. Yturbide" on Justia Law

The Supreme Court affirmed the decision of the Retirement Board of the Employee Retirement System of Providence (the Board) denying Petitioner's application for accidental disability retirement benefits and instead awarding her ordinary disability benefits, holding that there was legally competent evidence supporting the Board's decision to deny Petitioner accidental disability retirement benefits.Petitioner, who served as a bus monitor for the City of Providence, submitted an application for accidental-disability retirement benefits to Respondent, the Employees' Retirement System of Providence, alleging that she had suffered a work-related injury. The Board denied Petitioner's application and instead granted Petitioner ordinary disability benefits. The Supreme Court affirmed, holding that the Board based its decision on legally competent evidence that Petitioner's employment was not the natural and proximate cause of her disability. View "Trinidad v. Employees' Retirement System of Providence" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus against the State Highway Patrol Retirement System (HPRS), holding that Appellant was not entitled to an order compelling HPRS to vacate its finding that his disability was "not in the line of duty" and to grant disability retirement "in the line of duty."Appellant, a state trooper, applied to HPRS for permanent and total disability retirement benefits based on the diagnosis of an L5-S1 disk collapse and right-side disc bulge, as well as disintegration of L5-S1 vertebrae and arthritis. HPRS approved Appellant's disability but concluded that Appellant's condition did not occur in the line of duty. Appellant filed a complaint for a writ of mandamus, but the court of appeals denied the request. The Supreme Court affirmed, holding that Appellant failed to show that HPRS abused its discretion when it found that Appellant's injury did not occur in the line of duty. View "State ex rel. Seabolt v. State Highway Patrol Retirement System" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the decision of the Kansas Workers Compensation Board (Board) affirming an ALJ's denial of Helen Knoll's application for hearing with the Kansas Division of Workers Compensation (Division), holding that Kan. Stat. Ann. 44-523(f)(1) controlled Knoll's claim and required its dismissal.More than five years after Knoll filed her application with the Division, Employer moved to have Knoll's claim dismissed under section 44-523(f)(1) because the claim had not proceeded to a final hearing within three years of the filing of an application for hearing. The ALJ concluded that Knoll's motion for extension was timely and entered an award of compensation. The Board affirmed the ALJ's denial of the motion to dismiss. The Court of Appeals reversed, concluding that dismissal was appropriate because Knoll did not file a motion for extension within three years of filing her application for hearing. The Supreme Court affirmed, holding (1) if a workers compensation claimant filed an application for hearing under Kan. Stat. Ann. 44-534 after Kan. Stat. Ann. 44-523(f)(1) took effect in 2011, the 2011 statute governs the claim; and (2) because Knoll filed her application for hearing six months after the 2011 amendments became effective, section 44-523(f)(1) controlled her claim. View "Knoll v. Olathe School District No. 233" on Justia Law

Claimant Cozmin Gadalean, a commercial truck driver, was sent on a supervised delivery by and for employer as a pre-employment drive test. He was injured when he fell from employer’s truck. The Workers’ Compensation Board denied claimant coverage, concluding that he did not qualify as a worker at the time of the injury. The Court of Appeals reversed, holding that Oregon’s minimum wage laws would have entitled claimant to be paid for the delivery and that, therefore, he was a worker within the meaning of the workers’ compensation statute. The Oregon Supreme Court concluded the Court of Appeals erred, and affirmed the board’s denial of coverage. View "Gadalean v. SAIF" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the Workers' Compensation Board affirming the ALJ's determination that Appellant was not entitled to benefits pursuant to Ky. Rev. Stat. 342 in connection with his injury while working as a bus driver for Transit Authority of River City (TARC), holding that the ALJ's decision denying Appellant benefits was supported by substantial evidence.While operating a TARC bus Appellant was assaulted by a passenger, resulting in injuries. TARC denied Appellant's claim for benefits pursuant to the special defense provided in Ky. Rev. Stat. 342.610(3), asserting that Appellant was the aggressor in the altercation and that he acted outside of the scope of his employment. After reviewing the evidence, the ALJ denied Appellant benefits. The Board and the court of appeals affirmed. The Supreme Court affirmed, holding that there was substantial evidence supporting the ALJ's determination to deny benefits. View "Trevino v. Transit Authority of River City" on Justia Law

In this appeal concerning the statutory definition of "idiopathic causes" contained in the statute excluding benefits for certain accidents or injuries the Supreme Court held that the Workers Compensation Appeals Board improperly denied benefits to Terrill Graber, who was injured when he fell down a workplace stairway, holding that there was not substantial competent evidence to support the Board's finding that the accident or injury arose directly or indirectly from an idiopathic cause under the statutory exclusion.There was no evidence presented in this case showing why Graber fell down the workplace stairway. The Board construed the term "idiopathic causes" in Kan. Stat. Ann. 44-508(f)(3)(A)(iv) broadly to cover all unknown causes and denied compensation. The court of appeals reversed after defining the term more narrowly. The Supreme Court affirmed and remanded the case to the Board for reconsideration consistent with this opinion, holding that the term "idiopathic causes" in this context means medical conditions or medical events of unknown origin that are peculiar to the injured individual. View "Estate of Graber v. Dillon Companies" on Justia Law

The Supreme Court reversed the judgment of the Tenth District Court of Appeals granting Sharon Vonderheide's petition for a writ of mandamus and ordering the Industrial Commission to vacate its decision denying Vonderheide's request for temporary total disability (TTD) compensation, holding that "some evidence" supported the Commission's decision.The Commission denied Vonderheide's request for TTD compensation after she had surgery on her right knee, finding that Vonderheide failed to establish that she was in the workforce and had wages to replace as of the date of her surgery. The court of appeals granted Vonderheide's mandamus petition, holding that the Commission's decision was an abuse of discretion because it was not based on "some evidence." The Supreme Court reversed, holding (1) the court of appeals erred by disregarding the directive that an order that is supported by "some evidence" will be upheld; and (2) Vonderheide did not show a need for oral argument. View "State ex rel. Vonderheide v. Multi-Color Corp." on Justia Law