Schlumberger Technology Corp. and Travelers Indemnity Co. of America v. Erasmo Paredes and The Workers' Compensation Commission

Summary

The Oklahoma Supreme Court affirmed a Workers’ Compensation Commission order holding that Erasmo Paredes’s claim was timely filed under the Administrative Workers’ Compensation Act. The Court interpreted 85A O.S. Supp. 2019, § 69(A)(1) to allow the claimant the benefit of the longer limitations period when the one-year injury period and six-month period following the last benefits payment differ. The Court also concluded that the contrary interpretation would raise due process concerns because an employer’s payment of benefits could shorten the limitations period without notice to the employee.

Holdings

1. Section 69(A)(1) must be interpreted to allow a workers' compensation claimant to file within the longer of one year from the date of injury or six months from the date of the last issuance of benefits.
2. An interpretation of § 69(A)(1) that permits an employer or insurer, without notice to the employee, to shorten the employee's limitations period based on the date of a benefit payment would violate due process.
3. The Supreme Court reviews the Commission's interpretation of workers' compensation statutes de novo, without deference.

Questions Presented

1. Whether 85A O.S. Supp. 2019, § 69(A)(1) gives an injured employee the longer of one year from the date of injury or six months from the last issuance of benefits.
2. Whether applying the six-month period from the last benefit payment to shorten the one-year period, without notice to the employee, would violate due process.
3. What standard of review applies to the Workers' Compensation Commission's interpretation of the statute.

Disposition

affirmed