Nolan v. Commissioner of Department of Industrial Accidents

Paula Eastwood (plaintiff) filed a claim for workers’-compensation benefits for three separate injuries against three insurers. The conciliator requested that a fourth insurer to be added to the claim. Eastwood argued that it was not necessary, so the conciliator withdrew the claim. The senior judge of the Department of Industrial Accidents (the senior judge) (defendant) affirmed the withdrawal, finding Eastwood had failed to provide requested documents and had failed to add the fourth insurer to her claim. Valerie Sullivan (plaintiff) filed a claim for benefits against one insurer. The insurer made a payment to her after the statutory deadline, so Sullivan filed a claim for a late-payment penalty. The conciliator extended the conciliation period pursuant to statutory law. However, no consultation occurred, and there was no record put in the file. The conciliator withdrew the claim, and the senior judge affirmed. Emile Tabea (plaintiff) filed a claim for benefits after he suffered a back injury. Tabea missed work because of his injury. Tabea did not seek medical treatment for each day he missed work. The conciliator requested treatment records for each day Tabea was absent from work, but Tabea did not have documentation to provide. The conciliator withdrew the claim, and the senior judge affirmed. Alvarez Hinton (plaintiff) filed a claim for total-disability benefits. Hinton provided documents from his treating physician, but they did not state he was totally disabled. Due to a lack of sufficient documentation, the conciliator withdrew the claim. Hinton did not allege what decision the senior judge issued after Hinton appealed the withdrawal. Eastwood, Sullivan, Tabea, and Hinton (collectively, the claimants) sued the senior judge and the commissioner of the Department of Industrial Accidents for declaratory judgment, mandamus, and due-process-rights violations. The senior judge and the commissioner filed a motion to dismiss.