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Texas Workers' Compensation Insurance Fund v. Texas Workers' Compensation Board12/4/2003
The Texas Workers' Compensation Insurance Fund ("Texas Mutual") challenges the decision of an appeals panel of the Texas Workers' Compensation Commission (the "Commission"). The appeals panel reversed a Commission hearing officer's decision and awarded lifetime income benefits to the claimant, Leonard D. Watts ("Watts" or the "claimant"), for injuries Watts received during the course and scope of his employment as a truck driver for Mono Chem Corporation. Texas Mutual appealed, and a Travis County district court determined that the appeals panel acted outside of its statutory authority in reversing the decision of the hearing officer. See Tex. Lab. Code Ann. § 410.204(a) (West Supp. 2004). The district court set aside the appeals-panel decision but refused to reinstate the decision of the hearing officer, as was requested by Texas Mutual. See id. § 410.204(c) (West Supp. 2004).
In this cross-appeal, Texas Mutual argues in one issue that the district court erred in refusing to reinstate the decision of the hearing officer. The Commission also appeals and argues that (1) the district court erred in denying the Commission's motion to transfer venue to Upshur County and (2) Texas Mutual cannot bring a declaratory-judgment action because it is redundant to judicial-review remedies expressly provided for under the labor code. We will reverse the decision of the district court and render judgment in favor of the Commission.
BACKGROUND AND PROCEDURE
Workers' Compensation Adjudication of Disputes
In order to appropriately frame the facts of this case, we will briefly review the types of benefits and the process for adjudication of disputes under the Texas Workers' Compensation Act (the "Act"). See id. §§ 401.011(5) (West Supp. 2004) (benefits generally), 408.081-.162 (West 1996 & Supp. 2004) (income benefits), 410.001-.308 (West 1996 & Supp. 2004) (adjudication of disputes). The Act divides benefits into four separate categories: medical, income, death, and burial. See id. § 401.011(5). The category of income benefits is itself divided into four parts: (1) temporary income benefits; (2) impairment income benefits; (3) supplemental income benefits; and (4) lifetime income benefits. See generally id. §§ 408.081-.162. These four types of income benefits are distinct from one another, Texas Gen. Indem. Co. v. Texas Workers' Comp. Comm'n, 36 S.W.3d 635, 640 (Tex. App.--Austin 2000, no pet.), and are discussed in separate subchapters of the Act. See Tex. Lab. Code Ann. §§ 408.101-.103 (temporary income benefits), .121-.129 (impairment income benefits), .141-.150 (supplemental income benefits), .161-.162 (lifetime income benefits).
Temporary income benefits compensate for lost wages while an injured employee is convalescing. Texas Workers' Comp. Comm'n v. Garcia, 893 S.W.2d 504, 513 (Tex. 1995). They accrue when an employee suffers a disability and continue until "maximum medical improvement." Tex. Lab. Code Ann. §§ 408.101-.102 (West 1996); Garcia, 893 S.W.2d at 513. Lifetime income benefits, on the other hand, are paid until the death of the employee and compensate for certain enumerated conditions, including the loss of use of both feet at or above the ankle. See Tex. Lab. Code Ann. § 408.161(a), (b) (West Supp. 2004).
Chapter 410 of the Act establishes a multi-tiered system for the determination of claims. Texas Workers' Comp. Comm'n v. Bridge City, 900 S.W.2d 411, 412 (Tex. App.--Austin 1995, writ denied). Subchapter B of chapter 410 provides first for the informal resolution of claims through a non-adversarial conference conducted by a "benefit review officer" who may render an interlocutory order determining whether benefits are to
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