Bahmiller v. North Dakota Workforce Safety & Insurance

Summary

The North Dakota Supreme Court affirmed a district court judgment reversing an administrative order that denied Bruce Bahmiller workers’ compensation benefits as untimely. The Court held that the evidence did not establish that Bahmiller knew or should have known before April 12, 2019, that he had a compensable work-related carpal tunnel injury. Because the condition was complex and insidious and no medical advice linked it to his employment before 2019, the claim was timely under N.D.C.C. § 65-05-01.

Holdings

1. Bahmiller's claim was timely because the evidence did not establish that he knew or should have known before April 12, 2019, that he suffered a compensable work-related injury. For a complex, insidious condition whose work-related cause is not apparent to a reasonable layperson, medical advice linking the condition to employment is required to trigger the limitations period under N.D.C.C. § 65-05-01.

Questions Presented

1. Whether Bahmiller's workers' compensation claim was timely under N.D.C.C. § 65-05-01.
2. Whether the ALJ's finding that Bahmiller knew or should have known in 2013 that he suffered a compensable work-related injury was supported by the weight of the evidence.
3. For a complex, insidious condition such as carpal tunnel syndrome, whether the limitations period begins before the claimant receives medical advice linking the condition to employment.

Disposition

affirmed