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Clifford Austin v. AM Mechanical Services

Decision date: February 3, 2021Injury #11-11201125 pages

Summary

The Missouri Court of Appeals reversed the Commission's initial decision, and upon remand, the Commission affirmed that the employee's Kansas workers' compensation settlement validly barred him from pursuing a Missouri claim for the same March 10, 2011 workplace injury. The Commission found no fraud or duress in the Kansas settlement and upheld the employee's voluntary waiver of his right to pursue claims in other jurisdictions.

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Third-Party Injury Check

This workers' comp decision may point to a separate injury claim.

  • A driver, contractor, property owner, or equipment company may share fault.
  • The injury involved a vehicle, unsafe premises, defective equipment, or a non-employer vendor.
  • A serious injury or death may need both benefits review and civil-claim analysis.

Caption

Issued by THE LABOR AND INDUSTRIAL RELATIONS COMMISSION

FINAL AWARD ALLOWING COMPENSATION

(After Mandate from the Missouri Court of Appeals Western District)

**Injury No.:** 11-112011

**Employee:** Clifford Austin

**Employer:** AM Mechanical Services

**Insurer:** AMCO Insurance Company

**Additional Party:** Treasurer of Missouri as Custodian of Second Injury Fund

On March 10, 2020, the Missouri Court of Appeals, Western District, issued an opinion reversing the May 1, 2019, award and decision of the Labor and Industrial Relations Commission (Commission). *Clifford Austin v. AM Mechanical Services, Treasurer of the State of Missouri-Custodian of Second Injury Fund, WD 82778 (March 10, 2020)*. By mandate dated September 2, 2020, the court confirmed its decision to reverse the Commission's award and decision and remanded this matter to the Commission for further proceedings consistent with the court's opinion.

In its decision, the court found that the employee's claim was timely filed with the Missouri Division of Workers' Compensation (Division) pursuant to § 287.430. The court further found that the Commission, by adopting the administrative law judge's factual findings, determined that the Division and the State of Kansas had dual jurisdiction over employee's March 10, 2011, workplace injury. Pursuant to court's express directive and mandate, we issue this award.

Discussion

In addition to the issues of the statute of limitations and jurisdiction, the administrative law judge's award addressed the following disputed issues:

  1. Whether employer/insurer procured employee's Kansas settlement by fraud or duress.
  2. Whether the terms of employee's February 28, 2013, Kansas workers' compensation settlement with employer/insurer, including employee's agreement to close out all claims in all jurisdictions related to his March 10, 2011, work injury, barred employee from pursuing a Missouri workers' compensation claim for the same injury.
  3. The Second Injury Fund's liability.

Whether employer/insurer procured employee's Kansas settlement by fraud or duress. The transcript of the February 28, 2013, settlement hearing before Kansas Division of Workers' Compensation Special Administrative Law Judge Jerry Shelor documents employee's pro se appearance and his request that the administrative law judge approve the settlement terms employer/insurer offered. Employer/insurer's attorney explained on the record that payment of the lump sum of $49,315.00 was "intended to close out any and all issues and injuries, any and all jurisdictions, and any dates of alleged accident that Mr. Austin may have sustained while working for AM Mechanical Service Company." *Transcript, 825*. The settlement was free of any attorney's fee lien.

Injury No.: 11-112011

Employee: Clifford Austin

- 2 -

and left the issue of future medical open. At the hearing of his Missouri claim, employee acknowledged that nothing prevented him from consulting an attorney to review employer/insurer's offer to settle his Kansas workers' compensation claim.

Employee's attorney cites no authority in support of his contention that the terms of employee's Kansas settlement with employer/insurer are not binding because the employer/insurer and the Kansas administrative law judge failed to fulfill his obligation to advise employee about his rights under Missouri law. We concur with the administrative law judge's conclusion that the unrepresented employee entered into a settlement of his claim against employer/insurer on February 28, 2013, and voluntarily waived his right to pursue a claim against employer/insurer in any other jurisdiction, of his own volition and free will. We find as a factual matter, that employer/insurer did not procure the Kansas settlement by fraud or duress.

Whether the terms of employee's February 28, 2013, Kansas workers' compensation settlement with employer/insurer, including employee's agreement to close out all claims in all jurisdictions related to his March 10, 2011, work injury, barred employee from pursuing a Missouri workers' compensation claim for the same injury.

We adopt the administrative law judge's legal analysis relating to application of the full faith and credit clause of the United States Constitution to a workers' compensation matter involving dual jurisdiction. After a thorough discussion of the relevant case law, the administrative law judge found that the full faith and credit clause of the United States Constitution barred employee from pursuing a Missouri claim against the employer/insurer in Missouri because no substantive differences in Missouri and Kansas workers' compensation law applied to employee's claim that the language of the Kansas settlement agreement, including a provision closing out all issues in all jurisdictions involving injuries employee sustained while working for employer/insurer, was based on a Kansas substantive law that differed from Missouri's substantive law.

We agree. On appeal to the Commission, the employee asserted that distinct provisions of Kansas and Missouri law referencing "impairment" vs "disability" constitute substantive differences between the two states' laws that preclude Missouri from according full faith and credit to the provisions of employee's Kansas settlement. Employee's Kansas settlement, however, included employee's acceptance of the amount of $49,315.00 as a strict compromise of all issues. The settlement then expressly listed issues that included not only the nature and extent of permanent partial impairment but also, inter alia, employee's work disability. Transcript, 828. Employee's claim that the Kansas settlement was limited to consideration of impairment without recognizing his work disability is plainly incorrect.

We therefore find, as a matter of law, that the United States Constitution's full faith and credit clause precludes employee from pursuing a subsequent claim in Missouri for the same workers' compensation injury against the employer/insurer herein.

Injury No.: 11-112011

Employee: Clifford Austin

- 3 -

**The Second Injury Fund's liability**

Because the court determined employee's claim timely and subject to Missouri jurisdiction, we now consider employee's Second Injury Fund claim. In language not essential to his award, the administrative law judge opined that employee's Kansas settlement with employer/insurer did not preclude employee from pursuing a claim against the Second Injury Fund in Missouri because the Second Injury Fund was not a party to employee's Kansas settlement. The Second Injury Fund did not appeal the administrative law judge's award.

We find that employee's agreement to settle any issues relating to this injury against employer/insurer in any jurisdiction does not preclude him from pursuing a Missouri claim against the Second Injury Fund, irrespective of whether the full faith and credit clause applies to the terms of employee's Kansas settlement.

**Nature and extent of disability**

To adjudicate employee's Second Injury Fund claim we must first determine the amount of disability attributable to employee's primary injury. § 287.220. We are not bound by the 27% body as a whole percentage of permanent impairment referenced in employee's Kansas settlement with employer/insurer. However, given employee's agreement to accept this amount in settlement all issues he might have raised in a regular hearing, including work disability, we rely on this assessment as the basis for our factual finding that employee sustained 27% permanent partial disability of the body as a whole related to his primary March 10, 2011, work injury.

Dr. James Stuckmeyer was the only medical expert who evaluated employee's preexisting disability in combination with disability from the primary injury. In his July 19, 2017, report, Dr. Stuckmeyer reviewed a multitude of work restrictions resultant from employee's preexisting injuries and his primary injury. He recommended vocational assessment of employee's employability in the open labor market. Dr. Stuckmeyer opined in advance that if employee were found permanently and totally disabled his condition would be due to a combination of employee's significant preexisting disabilities in combination with disabilities from the March 10, 2011, primary injury.

We credit the opinion of employee's vocational expert Michael Dreiling, who found employee unemployable in the open labor market due to restrictions related to his primary injury and preexisting injuries. We assign little weight to the contrary opinion of employer/insurer's vocational expert Kevin Ross, who admitted that his Labor Market Survey Report misidentified employee as "Mr. Ortega" (Transcript, 989) and incorrectly stated that employee had a valid Illinois driver's license. Mr. Ross did not bolster his credibility when he further admitted that in the course of performing twenty-five assessments over a period of approximately a year and a half he found not a single employee unemployable.

We find employee is permanently and totally disabled as a result of the combination of disability from his March 10, 2011, primary injury and preexisting disabilities, as of December 21, 2012, the date of his release to return to work by Dr. Adrian Jackson.

Amend

We find the Second Injury Fund liable to employee for lifetime weekly permanent total disability benefits, as provided by law, starting December 21, 2012, the date employee reached maximum medical improvement, at the weekly rate of $\ 248.09 per week for 108 weeks, and at the rate of $\ 666.67 per week thereafter.

The award and decision of Administrative Law Judge Kenneth J. Cain, issued August 3, 2018, is attached and incorporated herein to the extent not inconsistent with this Final Award Allowing Compensation.

Keith V. Yarwood, Attorney at Law, is awarded a fee of 25 % of all compensation awarded for necessary legal services rendered to employee, which shall constitute a lien on said compensation.

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

Given at Jefferson City, State of Missouri, this $\qquad 3rd \qquad$ day of February 2021.

LABOR AND INDUSTRIAL RELATIONS COMMISSION

![img-0.jpeg](img-0.jpeg)

Robert W. Córnejo, Chairman

![img-1.jpeg](img-1.jpeg)

SEPARATE OPINION FILED

Shalonn K. Curls, Member

Attest:

![img-2.jpeg](img-2.jpeg)

Improved: Clifford Austin

SEPARATE OPINION

I concur with the majority's award pursuant to Western District Court of Appeals' mandate to the extent that it finds the Second Injury Fund liable for employee's permanent total disability.

I dissent from the award's finding that employee's Missouri claim against employer/insurer is barred by the terms of a settlement he entered into in Kansas purporting to preclude employee from pursuing any further claims against employer/insurer in any jurisdiction. I also disagree with the majority's assessment of the nature and extent of disability attributable to employee's primary injury.

An injured Missouri employee cannot waive his rights under Missouri law without the approval of a Missouri workers' compensation administrative law judge.

Employer/insurer required employee to waive his rights under the laws of every other state to collect his settlement for impairment under Kansas law. The employee agreed and a Kansas special administrative law judge approved the settlement. However, waiver of employee's right to pursue benefits under the Missouri Workers' Compensation Law is not enforceable under § 287.390.1 because employee was not fully informed of his rights under Missouri law and the settlement was not approved by a Missouri administrative law judge. Section 287.390.1 prohibits the Division from recognizing an agreement "by an employee or his or her dependents to waive his or her rights under this chapter."

Employee's waiver of rights under Missouri law pursuant to his Kansas workers' compensation settlement is invalid for two reasons: First, the special Kansas

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

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