Waite v. Utah Labor Commission

Summary

The Utah Supreme Court considers whether Utah Code section 34A-2-417(2)(a)(ii), which requires an injured worker to prove entitlement to workers’ compensation benefits within twelve years of the workplace accident, is a statute of repose. The court holds that the provision is a statute of repose but concludes that it does not violate the Utah Constitution’s Open Courts Clause. The opinion also addresses the applicable standard for reviewing the statute’s constitutionality and legislative judgments under the Berry framework.

Holdings

1. Section 34A-2-417(2)(a)(ii) is a statute of repose because its twelve-year period runs from the date of the workplace accident rather than from the accrual of the worker's right to claim additional benefits.
2. Section 34A-2-417(2)(a)(ii) is constitutional under the Open Courts Clause.
3. The court did not reach the Uniform Operation of Laws Clause challenge because the petitioners inadequately briefed it.

Questions Presented

1. Whether Utah Code section 34A-2-417(2)(a)(ii) is a statute of limitation or a statute of repose.
2. Whether section 34A-2-417(2)(a)(ii), as a statute of repose, violates the Open Courts Clause of article I, section 11 of the Utah Constitution.
3. Whether section 34A-2-417(2)(a)(ii) is facially unconstitutional under the Utah Constitution's Uniform Operation of Laws Clause.

Disposition

affirmed