Coates v. Fallin

316 P.3d 924 (2013)

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Coates v. Fallin

Oklahoma Supreme Court
316 P.3d 924 (2013)

Facts

Senate Bill 1062 (the bill) repealed the Workers’ Compensation Code and replaced it with the Administrative Workers’ Compensation Act (AWCA). The bill adopted the Oklahoma Employee Injury Benefit Act (IBA) and the Workers’ Arbitration Compensation Act. The bill also provided for the Workers’ Compensation Court of Existing Claims for claims before February 1, 2014. The IBA provided an appeals process for workers of employers that opted out of the new system. Employers had the ability to opt out of the new system but had to provide claimants with the ability to appeal to a committee of at least three individuals who were not involved in the original adverse benefit determination. If part of the adverse decision was upheld by the committee, the employee could file a petition for review with the Workers’ Compensation Commission. However, the standard of review was different for workers of employers that had opted out versus workers of employers that had not. Additionally, by opting out, employers had the ability to choose the appeals committee, forgoing impartiality. Workers of employers that had not opted out were able to have their claims heard by an administrative-law judge, who had to remain impartial. The AWCA made same-sex spouses ineligible for death benefits and excluded coverage for mental injuries that were not accompanied by physical injuries. The IBA allowed for compensation if there was impairment without complete loss of use of a body part and treated a permanently impaired worker the same as one who had a partial disability. Additionally, the IBA did not allow for the development of a sufficient record. There was a constitutional challenge to the bill in which it was argued that the legislature acted outside its authority by enacting a bill that contained multiple subjects in violation of the Oklahoma constitution.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

Concurrence (Combs, J.)

Concurrence/Dissent (Reif, J.)

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