Boise, ID (WorkersCompensation.com) – As a recent case showed, lump sum settlements can change the course of an employee’s quest for benefits, but state-specific contours also figure in.
According to Idaho’s highest court in Stanley v. Industrial Special Indemnity Fund, 481 P.3d 731 (Idaho 02/17/21), a statute of limitations that normally applies to workers’ compensation claims involving settlements doesn’t come into play when the state’s Industrial Special Indemnity Fund is involved.
Injury, Settlement
A worker for a cooperative experienced an injury to his left shoulder and lower back on the job. He filed a workers’ compensation claim and the Idaho State Insurance Fund paid the worker $52,663.54 in temporary total and temporary partial disability benefits.
The worker entered into a lump sum agreement with the cooperative and the fund under which the fund agreed to pay the worker and additional $40,000 for disputed past medical and disability benefits.
After the settlement, the worker underwent surgery and alleged that the culmination of his prior injuries and the surgery rendered him totally and permanent disabled. The ISIF denied the worker’s claim for lifetime benefits, contending that the state’s statute of limitations barred the claim after the settlement agreement.
The worker filed a complaint with the state’s workers’ compensation commission, countering that the agreement left the issue of future medical benefits open.
The commission agreed with the ISIF and dismissed the worker’s case, prompting him to appeal to the Idaho Supreme Court.
The law at issue placed time limits on when an employee could file a claim against an “employer or surety” but made no mention of the ISIF.
‘Employer’ or ‘Surety’?
Because of this, the Idaho Supreme Court found that the statute of limitations did not prevent the worker from filing his claim, and it reversed the commission’s ruling against him.
The court noted that the worker settled his underlying claim against the cooperative and the state insurance fund by accepting the lump sum. However, after the settlement, he alleged that the combined effects of his subsequent injury and the underlying injury raised new compensability issues that he pursued in his claim against the ISIF.
Because the statute of limitations at issue did not apply to the ISIF and because the worker adhered to state law requirements, the court found that his claim go forward.
It reasoned that workers’ compensations laws were “meant to protect” injured employees without requiring them “to incur substantial costs in litigating” claims.
Thus, the court reversed the commission’s decision, giving the worker another shot at his claim against the ISIF.
