|Opinion:||Schlumberger Technology Corp. v. Paredes, 2023 OK 42|
|Subject Matter:||Statutory Interpretation–Workers’ Compensation|
|Trial Court:||Workers’ Compensation Commission|
|Route to this Court:||Schlumberger appealed from the Administrative Law Judge’s decision to the Workers’ Compensation Commission. The Commission, sitting en banc, affirmed the ALJ’s decision. Schlumberger appealed the Commission’s affirmation.|
|Facts:||Paredes sustained an on-the-job injury on December 29, 2019. He continued working for a month and received medical treatment from employer’s provider Travelers Indemnity Company of America from January 3 to February 14, 2020. Paredes filed a CC-Form 3 Claim for Compensation on December 3, 2020 alleging an injury date on December 29, 2019. Therefore, the complaint was filed ten months after his last medical treatment, but within a year from the time of his injury. Travelers filed an affidavit affirming that it had paid $1,371.47 in medical treatment and did not pay disability benefits. Travelers also raised a statute of limitations defense on behalf of Schlumberger pursuant to 85A O.S. Supp. 2019, § 69(A)(1).|
An Administrative Law Judge and the Workers’ Compensation Commission both affirmed that the claim was not barred by 85A O.S. Supp. 2019, § 69(A)(1). Schlumberger appealed to the Court seeking review of the Commission’s interpretation of the statute.
|Standard of Review:||The issue presented in this case is an issue of statutory interpretation, thus a question of law which the Court reviewed de novo. Maxwell v. Sprint PCS, 2016 OK 41.|
|Analysis:||The Court first looked to the text of 85A O.S. Supp. 2019, § 69(A)(1), which states that “A claim for benefits under this act . . . shall be barred unless it is filed with the Workers’ Compensation Commission within one (1) year from the date of the injury or, if the employee has received benefits under this title for the injury, six (6) months from the date of the last issuance of such benefits.” Schlumberger argued that the clause subsequent to “or” shortened the period to six months in which an employee could file a claim for benefits. Paredes argued that the language allowed for filing within a year of the date of the injury or within six months after receiving benefits, whichever is longer.|
In light of the text, the Court analyzed the statutory background of 85A O.S. Supp. 2019, § 69(A)(1) from 1941 to 2001. During that time, the statute of limitations for filing claims for workers’ compensation was drafted and amended in 1941, 1981, 1997, and 2001. In each version, the statute of limitations was structured so as to provide workers ample time to file a claim. Despite the fact that the Legislature left out the words “whichever is greater” from 85A’s text, the statute of limitations was never shortened based on payment of benefits by the employer.
The Court then looked to the purpose of the statute of limitations. Relying on Seitz v. Jones, 1961 OK 283, wherein the Court said that “the underlying purpose of the statute of limitations is to prevent the unexpected effort at enforcement of stale claims concerning which persons interested have been thrown off their guard by want of prosecution for a long time.” There was nothing in the record to indicate that Paredes was neglectful of his rights and Schlumberger’s ability to defend this claim was not hampered. Finally, relying on the rule to interpret statutes so as to avoid constitutional doubt, the Court upheld Paredes’s interpretation as being constitutional. The issue in this case was that Paredes received no notice that the medical bills had been paid by Travelers. Therefore, in order to comply with due process, the obligations of the Administrative Workers’ Compensation Act on both employee and employer begin with notice requirements. Because Schlumberger’s interpretation of the statute would do away with the notice requirement, such a construction would violate due process. Therefore, the Administrative Law Judge and the Workers’ Compensation Commission properly held that Paredes was not barred by the statute of limitations.
|Vote:||6-3. Rowe, V.C.J., Kauger, Edmondson, Combs, Gurich (author), and Darby, JJ. concur. Kane, C.J., (by separate writing), Kuehn, J., and Downing, S.J., dissent. Winchester, J. disqualified.|
|Other:||Chief Justice Kane, joined by Justices Kuehn and Downing, dissented from the majority opinion for three primary reasons. First, the Majority’s opinion ran contrary to the plain language of 85A O.S. Supp. 2019, § 69(A)(1). The statute clearly has two terms for the statute of limitations: (1) a year from the date of injury or (2) six months from the date of the last issuance of such benefits. The language could not have been clearer and the amendments to the statute supported such a construction. The Chief Justice pointed out that in 2019, the Legislature amended § 69 by reducing both limitations periods and deleted the language “whichever is greater.” This came after Green County Physical Therapy L.P. v. Sylvester, 2018 OK CIV APP 64, where the Court of Appeals held that the a claim filed more than two years from the date of the injury was timely. Therefore, the Legislature was explicit in intending to limit the period to file after receiving benefits to six months. Furthermore, the Chief Justice noted that Paredes received medical treatment and was released by his treating physician at maximum medical improvement. It seemed likely that he would have known that his medical bills had been paid after being admitted and then released from hospital care. Therefore, the Majority erred in interpreting 85A contrary to the plain language and legislative intent.|