In re Crawford & Company, Crawford & Company Healthcare Management, Inc., Patsy Hogan and Old Republic Insurance Company

Summary

The Supreme Court of Texas conditionally granted mandamus relief in a workers’ compensation dispute involving claims against an insurer, claims administrators, and an employee. The court held that the Division of Workers’ Compensation has exclusive jurisdiction over claims arising from the investigation, handling, and settlement of workers’ compensation benefits, regardless of the legal label or damages sought. Because the plaintiffs had not exhausted administrative remedies, the trial court was directed to dismiss the claims for lack of subject-matter jurisdiction.

Holdings

1. The Division of Workers’ Compensation has exclusive jurisdiction over claims arising out of a workers’ compensation carrier’s investigation, handling, or settlement of a claim for benefits, and the Workers’ Compensation Act provides the exclusive procedures and remedies for those claims.
2. Whether the Act supplies the exclusive process and remedies depends on the substance of the claim and the conduct underlying it, not on the label of the cause of action or the nature of the relief sought.
3. The Division has exclusive jurisdiction over misrepresentation, fraud, malicious prosecution, and intentional-infliction-of-emotional-distress claims when the alleged conduct occurred in connection with the investigation, handling, or settlement of workers’ compensation benefits.
4. Even assuming Natalie Johnson has standing to assert her claims, her claims fall within the Division’s exclusive jurisdiction because they arise from Crawford’s conduct in investigating, handling, and settling Glenn Johnson’s workers’ compensation claim.
5. Mandamus relief was warranted because the trial court lacked subject-matter jurisdiction over the unexhausted claims and should have dismissed them.

Questions Presented

1. Whether the Texas Workers’ Compensation Act gives the Division of Workers’ Compensation exclusive jurisdiction over claims arising from a carrier’s investigation, handling, or settlement of a workers’ compensation benefits claim.
2. Whether the exclusive-jurisdiction rule applies based on the substance of the claims rather than the labels attached to the causes of action.
3. Whether claims for misrepresentation, fraud, malicious prosecution, and intentional infliction of emotional distress are outside the Act merely because they seek damages characterized as independent of workers’ compensation benefits.
4. Whether Natalie Johnson’s status as a nonemployee places her claims outside the Division’s exclusive jurisdiction.
5. Whether mandamus relief should issue to require dismissal for failure to exhaust administrative remedies.

Disposition

writ_granted