Benson v. Utah Labor Comm'n
2018 UT App 228
Utah Ct. App.2018Background
- Rodney Benson sought workers’ compensation benefits from the Utah Labor Commission, claiming a workplace knee injury required replacement surgery.
- The Labor Commission (ALJ and Appeals Board) denied benefits, finding Benson’s knee problems stemmed from a prior motorcycle accident and degenerative factors, not the industrial accident.
- Benson petitioned for judicial review in the Utah Court of Appeals challenging procedural and constitutional aspects of the Commission’s proceedings and alleging bias.
- He argued he was constitutionally entitled to a jury trial and that statutes, the executive branch, and the Commission were biased against workers and against him specifically.
- The Court of Appeals evaluated procedural briefing deficiencies, constitutional arguments, alleged bias, and whether the Commission’s medical causation finding was supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to jury trial in Labor Commission proceedings | Benson: Article I, §10 entitles him to jury trial in formal adjudication | Commission: Administrative proceedings are statutory and not jury-triable | No jury right; claim fails under Utah precedent and Seventh Amendment inapplicability to admin adjudication |
| Constitutional violations by Legislature/Commission | Benson: Various federal/state constitutional provisions violated by statutes and process | Commission: Arguments inadequately briefed and unsupported | Rejected for inadequate briefing and lack of developed legal analysis |
| Alleged institutional and personal bias | Benson: Legislature/exec/Commission biased against workers and him | Commission: No demonstrated constitutional or statutory violations; procedures followed | Rejected; Benson showed no specific constitutional recusal/bias claim and failed to cite unmet procedural rules |
| Medical causation for benefits | Benson: Knee replacement caused by industrial accident | Commission: Medical panel and records show preexisting motorcycle injury and degenerative causes | Affirmed: substantial evidence (medical panel report and records) supports Commission’s finding of only temporary aggravation resolved within a year |
Key Cases Cited
- Jensen v. State Tax Comm’n, 835 P.2d 965 (Utah 1992) (jury-trial right limited to actions triable by jury at Constitution’s adoption)
- Curtis v. Loether, 415 U.S. 189 (1974) (Seventh Amendment generally inapplicable to administrative proceedings)
- Smith v. Four Corners Mental Health Ctr., Inc., 70 P.3d 904 (Utah 2003) (appellate briefs must provide reasoned analysis and authority)
- Simmons Media Group, LLC v. Waykar, LLC, 335 P.3d 885 (Utah Ct. App. 2014) (inadequately briefed claims fail to meet appellant’s burden)
- University of Utah v. Shurtleff, 144 P.3d 1109 (Utah 2006) (policy issues for Legislature when no constitutional infirmity shown)
- Danny’s Drywall v. Labor Commission, 339 P.3d 624 (Utah Ct. App. 2014) (awarding benefits is mixed question of fact and law)
- Jex v. Labor Commission, 306 P.3d 799 (Utah 2013) (deference depends on whether question is fact-like or law-like)
- Carbon County v. Workforce Appeals Bd., 308 P.3d 477 (Utah 2013) (fact-intensive agency inquiries warrant appellate deference)
- Hutchings v. Labor Commission, 378 P.3d 1273 (Utah Ct. App. 2016) (medical causation is a factual determination; medical panel report can supply substantial evidence)