Yaumary Concepcion Torres v. Seaboard Foods, LLC, American Zurich Ins. Co., and the Workers' Compensation Commission

Summary

The Oklahoma Supreme Court held that 85A O.S. § 2(14), which required an employee alleging cumulative trauma to have completed 180 days of continuous employment, violated the Due Process Section of the Oklahoma Constitution as applied to the petitioner. The Court concluded that the statute's classifications were not rationally related to the asserted interests of preventing workers' compensation fraud and reducing employers' costs. The Workers' Compensation Commission's order was reversed, and the proceeding was remanded.

Holdings

1. 85A O.S. Supp. 2013 § 2(14) violates the Due Process Section of the Oklahoma Constitution, Okla. Const. art. 2, § 7, as applied to Torres because its overinclusive and underinclusive classifications are not rationally related to legitimate state interests.
2. The court did not decide the constitutionality of § 5 or whether § 5 independently barred a district-court remedy.
3. The court did not adjudicate Torres's claims under Okla. Const. art. 2, § 6, her broader challenge to the workers' compensation statutes, or her argument that the statutory scheme violated the workers' compensation 'grand bargain.'

Questions Presented

1. Whether 85A O.S. Supp. 2013 § 2(14)'s requirement that an employee complete 180 continuous days of employment before filing a cumulative-trauma claim violates the Due Process Section of the Oklahoma Constitution as applied to Torres.
2. Whether the 180-day classification is rationally related to the asserted state interests of preventing workers' compensation fraud and reducing employers' costs.
3. Whether the court needed to decide Torres's broader challenges to § 5, Article 2, § 6 of the Oklahoma Constitution, or the alleged workers' compensation 'grand bargain.'

Disposition

reversed_and_remanded