Naomi Reeder v. Zinc Corporation of America; Ace American Insurance Company and the Workers' Compensation Court

Summary

The Oklahoma Supreme Court held that 85 O.S. § 3.6(G), which directs that workers' compensation interest be computed pursuant to 12 O.S. § 727, incorporates only the applicable interest rate and does not authorize prejudgment interest on workers' compensation awards. The court sustained the denial of Naomi Reeder's request to add prejudgment interest to her death-benefit award.

Holdings

1. Section 3.6(G) incorporates the interest rate prescribed by 12 O.S. § 727 for computing interest authorized under § 3.6; it does not incorporate § 727 as a general source of authority to award prejudgment or post-award interest.
2. Prejudgment interest is not authorized on the workers' compensation death-benefit award because neither 85 O.S. § 3.6 nor another provision of the Workers' Compensation Act authorizes it.

Questions Presented

1. Whether 85 O.S. § 3.6(G), which provides that interest shall be computed pursuant to 12 O.S. § 727, incorporates all of § 727, including its prejudgment-interest provisions.
2. Whether the Workers' Compensation Act authorizes prejudgment interest on workers' compensation death-benefit awards.

Disposition

affirmed