Multiple Injury Trust Fund v. Coburn; Multiple Injury Trust Fund v. Sturdivant; Multiple Injury Trust Fund v. Crosslin; Multiple Injury Trust Fund v. Williams

Summary

The Oklahoma Supreme Court reviewed four companion proceedings involving the Multiple Injury Trust Fund's obligation to continue periodic attorney-fee payments after the injured claimants died. The Court held that 85 O.S. Supp. 2005 § 172(H), rather than § 30(D), governed the fees; that the Workers' Compensation Court of Existing Claims had jurisdiction to interpret and enforce its prior orders; and that § 172(H) was not an unconstitutional special law.

Holdings

1. The Oklahoma Supreme Court has jurisdiction to review a decision of the Workers' Compensation Court of Existing Claims when an aggrieved party files a timely petition for review in accordance with the law in effect before February 1, 2014.
2. The Workers' Compensation Court of Existing Claims has jurisdiction to determine whether the Multiple Injury Trust Fund made payments required by its previous final orders.
3. The Fund's liability for attorney's fees in these cases is governed by the specific statute, 85 O.S.Supp.2005 § 172(H), rather than the general attorney's-fee provision in § 30(D).
4. Attorney's fees awarded under § 172(H) are not limited to twenty percent of 400 weeks of compensation or to benefits actually paid before the claimant's death; the fees are vested based on the permanent-disability benefits awarded.
5. 85 O.S.Supp.2005 § 172(H) is not an unconstitutional special law.

Questions Presented

1. Whether the Oklahoma Supreme Court had jurisdiction to review decisions of the Workers' Compensation Court of Existing Claims through timely petitions filed under the law in effect before February 1, 2014.
2. Whether the Workers' Compensation Court of Existing Claims had jurisdiction to interpret its prior final orders and determine whether the Multiple Injury Trust Fund had made the required attorney's-fee payments.
3. Whether 85 O.S.Supp.2005 § 172(H), rather than 85 O.S.Supp.2005 § 30(D), governed the amount and payment of attorney's fees owed by the Multiple Injury Trust Fund.
4. Whether 85 O.S.Supp.2005 § 172(H) was an unconstitutional special law under article 5, section 59 of the Oklahoma Constitution.

Disposition

affirmed