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 sustained work-related injuries to her lower back, left hip, and right leg in 2009 when a semi-truck she was in rolled over. She filed a complaint for compensation benefits in 2011, and the Employer/Insurer began paying indemnity benefits in 2012. However, the Employer/Insurer repeatedly denied medical benefits, leading to multiple applications for bad faith and unfair claim processing by the Worker (paras 3-4).
Procedural History
- Lay v. CC Jones Trucking, A-1-CA-38737: The Court of Appeals reversed and remanded the case for reconsideration of the Worker's bad faith and unfair claim processing claims, holding that the Employer/Insurer must comply with the procedure set forth in the 2018 order (para 6).
Parties' Submissions
- Worker-Appellant: Argued that the benefit penalties should be calculated as a percentage of all benefits ordered by compensation orders, not just the benefits improperly denied (para 8).
- Employer/Insurer-Appellee: [Not applicable or not found]
Legal Issues
- Whether the Workers’ Compensation Judge erred in calculating the benefit penalties based on the value of the denied benefits rather than all benefits ordered by compensation orders (para 8).
Disposition
- The Court of Appeals affirmed the Workers’ Compensation Judge's amended order on remand (para 13).
Reasons
Per Duffy J. (Attrep and Ives JJ. concurring):
The Court found that the Workers’ Compensation Judge (WCJ) did not err in calculating the benefit penalties based on the value of the denied benefits. The WCJ's decision was consistent with the statutory language, which allows for a benefit penalty not to exceed twenty-five percent of the benefit amount ordered to be paid. The Court rejected the Worker's argument that the penalty should be based on all benefits ordered by compensation orders, noting that the statutory language does not support this interpretation. The Court also emphasized that the benefit penalty must be viewed in the context of the Workers’ Compensation Act's overall compromise of securing benefits and limiting monetary awards (paras 9-12).