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, an employee of Graceland N.M. LLC and Glen Metcalf, suffered a work-related injury on December 10, 2013, when a foreign object entered his right eye, leading to significant medical issues including a detached retina, scarred pupil, and removal of the eye lens. The Employer had no workers' compensation insurance at the time of the incident. The Worker underwent surgery and received medical care from various providers. After the Employer failed to meet its obligations under a settlement agreement, the Worker sought enforcement of compensation orders and sanctions against the New Mexico Uninsured Employers Fund (UEF) for bad faith or unfair claim-processing practices (paras 2-7).

Procedural History

• March 2015 Compensation Order: Settlement agreement reached, ordering Employer to pay for all medical billing and reimburse monies extended for Worker’s medical care.
• June 2015 Compensation Order: Supplemental order entered after Employer failed to meet obligations, reiterating Employer’s responsibilities.
• August 2015 Compensation Order: Ordered the UEF to process benefits in accordance with the March 2015 order due to Employer's defunct status.
• December 2016 Compensation Order: After Worker's condition worsened, a new compensation order was entered, requiring the UEF to pay Worker’s newly incurred medical bills, leaving previous orders in effect.
• July 2017 Order: Denied Worker’s application for enforcement of previous orders and sanctions against the UEF, finding UEF in compliance with the December 2016 order (paras 3-7).

Parties' Submissions

• Worker-Appellant: Argued that the UEF failed to fulfill its obligations under previous compensation orders, constituting bad faith or unfair claim-processing practices.
• Insurer-Appellee (UEF): Contended that the appeal was moot as Medicaid had already paid Worker’s medical bills, and it could not make payments until identified by Medicaid for reimbursement. Argued it was not subject to penalties for bad faith or unfair claim-processing practices (paras 8-9).

Legal Issues

• Whether the Workers' Compensation Judge (WCJ) failed to enforce prior compensation orders.
• Whether the WCJ erroneously declined to require the UEF to pay damages for bad faith and unfair claim-processing practices.

Disposition

• The Court of Appeals affirmed the WCJ's decision but remanded for a determination of whether Worker has exhausted the statutory limits on attorney fees and, if not, calculation of the proper attorney fee award for this appeal (para 25).

Reasons

• The Court of Appeals found that the UEF took steps on remand to ensure reimbursement of Medicaid and reviewed alleged unpaid medical bills, ordering payment pursuant to previous compensation orders or concluding no obligation to pay due to impermissible balance billing. The Court concluded that under these circumstances, the WCJ did not fail to enforce prior orders. Regarding bad faith or unfair claim-processing practices, the Court determined that the Worker did not persuade that the UEF is subject to such damages, affirming the WCJ’s denial of Worker’s application for damages on that basis. The Court also expressed concern over the UEF's conduct, noting unnecessary delays and lack of initiative in reimbursing Medicaid (paras 17-24).