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Dennis McBee v. WCA Waste Management Co.

Decision date: November 14, 201110 pages

Summary

The Commission affirmed the administrative law judge's award allowing workers' compensation for Dennis McBee's right shoulder injury sustained on May 22, 2009, finding that actual notice to the employer through the supervisor satisfied the notice requirements despite lack of formal written notice. The employer was not prejudiced by the failure to provide statutory written notice within 30 days, as it received timely actual notice and was able to investigate and arrange medical treatment.

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Caption

TEMPORARY AWARD ALLOWING COMPENSATION

(Affirming Award and Decision of Administrative Law Judge by Supplemental Opinion)

Injury No.: 09-101617

Employee: Dennis McBee

Employer: WCA Waste Management Co.

Insurer: New Hampshire Insurance Co.

The above-entitled workers' compensation case is submitted to the Labor and Industrial Relations Commission (Commission) for review as provided by § 287.480 RSMo. Having reviewed the evidence, read the briefs, heard the parties' arguments, and considered the whole record, the Commission finds that the award of the administrative law judge is supported by competent and substantial evidence and was made in accordance with the Missouri Workers' Compensation Law. Pursuant to § 286.090 RSMo, the Commission affirms the award and decision of the administrative law judge dated April 22, 2011, as supplemented herein.

Employer's notice defense under § 287.420 RSMo

We agree with the administrative law judge that employee's claim is not barred by his failure to provide written notice meeting the requirements of $\S 287.420$ RSMo. The administrative law judge, however, found that because employer received actual notice of employee's injury, employer "is prohibited from raising failure to receive written notice of claimant's injury as a defense." Award, page 5. Because nothing in the statute suggests that employer is "prohibited" from raising notice as a defense where it receives actual notice, we write this supplemental opinion to clear up any confusion and to apply the appropriate analysis under $\S 287.420$, which provides, in pertinent part, as follows:

No proceedings for compensation for any accident under this chapter shall be maintained unless written notice of the time, place and nature of the injury, and the name and address of the person injured, has been given to the employer no later than thirty days after the accident, unless the employer was not prejudiced by failure to receive the notice.

The purpose of the foregoing section is to give the employer timely opportunity to investigate the facts surrounding an alleged workplace accident and also to provide the employee with timely medical attention in order to minimize the effects of a work injury. Soos v. Mallinckrodt Chem. Co., 19 S.W.3d 683, 686 (Mo. App. 2000), overruled on other grounds by Hampton v. Big Boy Steel Erection, 121 S.W.3d 220, 224 (Mo. banc 2003). Employer was entitled to raise notice as a defense, and did so. As a result, employee was required to prove either (1) that he provided a written notice meeting all the requirements of $\S 287.420$ to the employer no later than 30 days after the accident; or (2) that the employer was not prejudiced by the employee's failure to provide timely notice. If employee fails to prove one or the other of these circumstances, his claim is barred. Sell v. Ozarks Med. Ctr., 333 S.W.3d 498, 510 (Mo. App. 2011).

Here, employee does not even allege that he provided written notice to employer that met each of the requirements under $\S 287.420$. Thus, the question is whether employee demonstrated that employer was not prejudiced by his failure to provide statutory notice of his right shoulder injury. The administrative law judge found that employee provided actual notice to employer when he told his supervisor, Ronnie Schenk, on May 22, 2009, that he had been injured at work that day. The administrative law judge heard the testimony from both employee and Mr. Schenk and found employee to be more credible on the question whether employee provided notice to Mr. Schenk. The administrative law judge explained his reason for believing employee's testimony over that provided by Mr. Schenk.

After carefully reviewing the testimony presented at the hearing and also the arguments of the parties in their briefs and oral arguments before this Commission, we discern no compelling basis for overturning the credibility determination of the administrative law judge, who, having viewed the live testimony from both employee and Mr. Schenk, was probably in a better position to make such findings. We agree with the administrative law judge that employee is more credible than Mr. Schenk. Accordingly, we affirm and adopt the administrative law judge's finding that employee provided actual notice of his right shoulder injury to Mr. Schenk on May 22, 2009, when, at the end of his shift that day, he went inside the office, told Mr. Schenk that he'd hurt his right shoulder, and even took off his shirt to show Mr. Schenk his injury.

Mr. Schenk, as we have mentioned, was employee's supervisor. As a result, Mr. Schenk's actual notice of employee's injury is imputed to employer. Sell, 333 S.W.3d at 510. Because employee provided actual notice to employer, the burden shifts to employer to demonstrate it was prejudiced by employee's failure to provide statutory notice. See Sell at 511: "[T]he burden of proving Employer's lack of prejudice in not receiving written notice rested on the Claimant. Once Claimant presented substantial evidence that Employer had actual notice of the relevant injury, however, the burden of showing prejudice then shifted to Employer." Thus, we see that under an appropriate § 287.420 analysis, employer is not "prohibited" from raising notice as a defense, but employer does have the burden of proving that it was prejudiced where it has actual notice of employee's injuries.

We find no evidence on the record to prove-let alone suggest-that employer was prejudiced by employee's failure to provide notice in the form required by statute. Mr. Schenk (and thus, employer) was aware of employee's injury the same day it occurred. Employer has failed to explain why, having received such notice, it was nevertheless disadvantaged by the lack of written notice meeting the requirements of $\S 287.420$ in its ability to either investigate the circumstances of the injury or to minimize its effects.

We note that each of employer's arguments are premised on the assumption that it did not have actual notice of employee's injury the same day it occurred. Because we have found otherwise, employer's arguments are unavailing. For example, employer argues that it was prejudiced because employee worked for months after his injury emptying trash cans and that this arguably made his shoulder worse-but employer ignores that this effectively occurred with its consent. After all, employer (through Mr. Schenk) knew about employee's untreated right shoulder injury when it sent him out to work his full duties after May 22, 2009. Employer also argues it was unable to investigate the injury,

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but again, this argument ignores the fact of actual notice and that nothing kept employer from investigating the incident as soon as May 22, 2009, at the end of employee's shift when employee showed Mr. Schenk his injury.

Ultimately, we conclude that employer was not prejudiced by employee's failure to provide written notice meeting the requirements of § 287.420 RSMo. Accordingly, employee's claim is not barred under that section.

Decision

We conclude that employee's claim for compensation is not barred by the notice requirement of § 287.420 RSMo. The award and decision of Chief Administrative Law Judge Nelson G. Allen, issued April 22, 2011, is affirmed and is hereby attached and incorporated to the extent it is not inconsistent with this supplemental opinion.

With regard to the administrative law judge's allowance of an attorney's fee herein, we note that in a filing with this Commission dated August 15, 2011, Stephen W. Holaday withdrew as employee's attorney and agreed to waive his right to a lien for any attorney fee for legal services rendered to employee in this matter. Accordingly, we do not affirm the administrative law judge's allowance of an attorney's fee to (or the attendant lien in favor of) Mr. Holaday.

Any past due compensation shall bear interest as provided by law.

This award is only temporary or partial. It is subject to further order, and the proceedings are hereby continued and kept open until a final award can be made. All parties should be aware of the provisions of § 287.510 RSMo.

Given at Jefferson City, State of Missouri, this 14th day of November 2011.

LABOR AND INDUSTRIAL RELATIONS COMMISSION

William F. Ringer, Chairman

Alice A. Bartlett, Member

CONCURRING OPINION FILED

Curtis E. Chick, Jr., Member

Attest:

Secretary

I write separately to disclose the fact that I did not participate in the September 28, 2011, oral argument in this matter. I have reviewed the evidence, read the briefs of the parties, and considered the whole record. I concur with the decision of the majority of the Commission.

Curtis E. Chick, Jr., Member

TEMPORARY OR PARTIAL AWARD

Employee: Dennis McBee

Injury No. 09-101617

Employer: WCA Waste Management Co.

Additional Party:

Insurer: New Hampshire Insurance Co.

Hearing Date: March 29, 2011

Checked by: NGA

  1. Are any benefits awarded herein? Yes.
  2. Was the injury or occupational disease compensable under Chapter 287? Yes.
  3. Was there an accident or incident of occupational disease under the Law? Yes.
  4. Date of accident or onset of occupational disease: May 22, 2009.
  5. State location where accident occurred or occupational disease was contracted: Livingston County, Missouri.
  6. Was above employee in employ of above employer at time of alleged accident or occupational disease? Yes.
  7. Did employer receive proper notice? Yes.
  8. Did accident or occupational disease arise out of and in the course of the employment? Yes.
  9. Was claim for compensation filed within time required by Law? Yes.
  10. Was employer insured by above insurer? Yes.
  11. Describe work employee was doing and how accident occurred or occupational disease contracted: Claimant was a trash truck operator and injured his right shoulder lifting a toilet that had water in it.
  12. Did accident or occupational disease cause death? No Date of death? N/A
  13. Part(s) of body injured by accident or occupational disease: Right shoulder.
  14. Compensation paid to date for temporary disability: None.
  1. Value necessary medical aid paid to date by employer/insurer? None.
  2. Value necessary medical aid not furnished by employer/insurer? None.
  3. Employee's average weekly wages:
  4. Weekly compensation rate: $410.34 / 410.34$
  5. Method wages computation: By stipulation.

COMPENSATION PAYABLE

  1. Amount of compensation payable:

Unpaid medical expenses:

weeks of temporary total disability (or temporary partial disability)

TOTAL: None.

Each of said payments to begin May 23, 2009 and be subject to modification and review as provided by law.

This Award is only temporary or partial, is subject to further order, and the proceedings are hereby continued and the case kept open until a final award can be made.

IF THIS AWARD IS NOT COMPLIED WITH, THE AMOUNT AWARDED HEREIN MAY BE DOUBLED IN THE FINAL AWARD, IF SUCH FINAL AWARD IS IN ACCORDANCE WITH THIS TEMPORARY AWARD.

The compensation awarded to the claimant shall be subject to a lien in the amount of $\mathbf{2 5 \%}$ of all payments hereunder in favor of the following attorney for necessary legal services rendered to the claimant: Stephen W. Holaday. The employer is hereby ordered and directed to provide claimant with such medical treatment including surgery to his right shoulder as may be reasonable and necessary to cure and relieve the claimant from the condition caused by claimant's accident on May 22, 2009.

FINDINGS OF FACT and RULINGS OF LAW:

Employee: Dennis McBee

Injury No. 09-101617

Employer: WCA Waste Management Co.

Additional Party:

Insurer: New Hampshire Insurance Co.

Hearing Date: March 29, 2011

Checked by: NGA

Prior to presenting evidence, the parties stipulated that the issues to be determined by this hearing are:

  1. Did the claimant on May 22, 2009 sustain an injury by accident arising out of and in the course of employment.
  2. Is the claimant barred from recovery by his failure to provide the employer with timely written notice of his alleged injury as provided by Section 287.420 RSMo.
  3. Liability of the

Full decision text continues in the plain-text archive copy.

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