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 on August 23, 2007, after falling off a semi-truck he was driving for the Employer. Disputes arose regarding the causal relationship of the Worker's left shoulder injury to the work accident. Settlement negotiations ensued, culminating in a verbal agreement on December 17, 2010, for a lump-sum payment and additional benefits. However, upon receiving photographs that allegedly questioned the extent of the Worker's disability, the Employer/Insurer attempted to withdraw the offer.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Worker: Argued that an enforceable settlement agreement was reached before the Employer/Insurer's withdrawal attempt, denying any fraud or misrepresentation on his part.
• Employer/Insurer: Contended that the settlement agreement was unenforceable due to non-compliance with statutory requirements and sought to withdraw the offer based on new evidence questioning the Worker's disability extent.

Legal Issues

• Whether the lump-sum settlement agreement between the Worker and Employer/Insurer is enforceable under NMSA 1978, Section 52-5-12(D) (2003) of the Workers’ Compensation Administration Act.
• Whether the Workers' Compensation Judge (WCJ) had the authority to approve the lump-sum settlement agreement under the Act prior to its 2009 amendments.

Disposition

• The Court of Appeals reversed the Workers’ Compensation Administration's order approving the lump-sum settlement agreement, finding it unenforceable due to non-compliance with statutory requirements.

Reasons

• The Court, led by Judge James J. Wechsler with concurrence from Judges Michael D. Bustamante and Jonathan B. Sutin, reasoned that the lump-sum agreement did not comply with the statutory requirements in effect at the time of the Worker's injury in 2007. Specifically, the agreement was impermissible as a lump-sum payment because it did not meet the exceptions outlined in Subsections B and C of Section 52-5-12, and the 2009 amendments to Subsection D, which could have allowed such an agreement, were not applicable to injuries occurring before their enactment. The Court also found that the agreement failed to comply with Sections 52-5-13 and 52-5-14 of the Act, as it was not presented to the WCJ in a joint petition signed by all parties and verified by the Worker or his dependents, nor did it meet the criteria for being fair, equitable, and consistent with the provisions of the Act. The Court concluded that the WCJ erred in approving the Agreement, emphasizing the Act's policy disfavoring lump-sum payments and the necessity for strict compliance with its requirements.