CHEYENNE – The Wyoming Supreme Court has reversed and remanded a decision made by Laramie County District Court Judge Thomas Campbell related to a workers’ compensation claim.
On Friday, the Supreme Court issued an opinion stating Jody J. Sweetalla did have a right to workers’ compensation for a shoulder injury, even though his employer at the time, Legend Services Inc., told him not to submit a claim.
In the opinion, the Supreme Court examined the issue of whether state Office of Administrative Hearings made an error when it upheld the Wyoming Department of Workforce Services’ Workers’ Compensation Division’s determination that Sweetalla didn’t file a benefits claim within the one-year statute of limitations set forth in Wyoming law.
In the district court ruling, Campbell affirmed the claim’s denial because he found Sweetalla’s “reliance on any representation made by the (department) was unreasonable,” and “equitable estoppel” couldn’t prevent the division from “asserting the statute of limitations as a defense.”
Equitable estoppel is a defense doctrine that states one person can’t take unfair advantage of another person through language or conduct that resulted in another person acting a certain way and caused their injury, according to USLegal.
According to the Supreme Court’s standard of review, the district court decision is ignored and the Supreme Court analyzes the facts directly from the workers’ services division. Sweetalla’s claim also involves a “mixed question of law and fact.”
The case stems around Sweetalla’s rights and responsibilities surrounding his employment’s termination. Sweetalla doesn’t deny that he did not submit a workers’ compensation claim within one year of the injury or the equitable estoppel finding.
However, Sweetalla did contest that the Department of Workforce Services made an error when it said equitable estoppel did not eliminate the statute of limitations in his workers compensation case.
“We have repeatedly recognized that equitable estoppel applies in workers’ compensation cases,” the Supreme Court said in its opinion. “We have applied it where either the employer or a (department) representative unintentionally made misleading statements to the claimant or the claimant’s representative, and to prevent the employer and the division from asserting a statue of limitations defense.”
According to court documents:
On Jan. 16, 2014, Sweetalla hurt his left shoulder as he was trying to open a garage door while he was working for Legend Services Inc. He told Legend Services about the injury and went to a doctor the same day the injury occurred.
Legend Services told Sweetalla not to file an injury report, and, in exchange, the company would keep Sweetalla on salary and pay his medical expenses. On Dec. 28, 2015, the company fired Sweetalla and told him it would no longer pay his medical expenses.
On Feb. 14, 2016, Sweetalla filed an injury report with the Wyoming Department of Workforce Services, but his claim was denied because the injury occurred more than a year earlier, and the department didn’t receive relevant medical records.
Sweetalla requested a contested case hearing and stated “my employer instructed me not to file for workers’ compensation. Both my employer and the division are estopped from raising the delay in filing as a bar to the claim.”
On Jan. 26, 2017, DWS responded to Sweetalla and upheld its decision that it would deny his claim because he filed it more than a year from when his injury occurred.
The Supreme Court ultimately found the department acted in error and reversed its decision.