BROWN v. CLAIMS MANAGEMENT RESOURCES INC.
2017 OK 13
| Okla. | 2017Background
- Employee Rodney Brown, a claims adjuster for Claims Management Resources (CMR), fell descending an interior stairwell after clocking out on March 25, 2014 and injured his knee.
- Brown worked on the second floor of a building CMR occupied (CMR occupied the entire second floor; CMR testimony supported ownership of the building though other tenants had access to the stairwell).
- Brown had to use a key card for parking/building access; he used the stairwell (instead of elevator) per an employer wellness program encouraging stair use.
- CMR denied compensability asserting two statutory exclusions: (1) the §2(13)(c) exclusion for injuries in a parking lot or other common area adjacent to the employer’s place of business before clock-in or after clock-out, and (2) the §2(9)(b)(3) exclusion for injury occurring when employment services are not being performed.
- The Administrative Law Judge and Workers’ Compensation Commission denied benefits; the Court of Civil Appeals affirmed. The Oklahoma Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether injury in interior stairwell after clocking out is within "course and scope of employment" (85A O.S. §2(13)) | Brown: stairwell was on employer premises and ingress/egress are integral to employment; he had not left the premises so §2(13)(c) inapplicable | CMR: injury occurred after clocking out in a common area adjacent to business, so §2(13)(c) excludes coverage | Held: Injury occurred on employer premises (not an "adjacent" common area) and §2(13)(c) did not apply; Brown was in course and scope of employment. |
| Whether injury is a "compensable injury" or excluded because "employment services" were not being performed (85A O.S. §2(9)(b)(3)) | Brown: clocking out and exiting via stairwell were required duties (ingress/egress), so he was performing employment services | CMR: Brown had stopped work by clocking out; therefore §2(9)(b)(3) excludes the injury | Held: "Employment services" includes required duties such as complying with employer exit procedures; Brown was performing employment services when injured — compensable. |
| Whether the interior stairwell is a "parking lot or other common area adjacent to an employer's place of business" (85A O.S. §2(13)(c)) | Brown: stairwell is on employer premises (CMR-owned building) and not an adjacent common area | CMR: stairwell was a common area used by other tenants and therefore falls within the exclusion | Held: Evidence showed CMR owned the building and stairwell was on the premises; the exclusion applies only to areas adjacent to the premises — it did not apply here. |
| Constitutional challenges to §§2(9)(b)(3) and 2(13)(c) (due process / adequate remedy) | Brown: statutory scheme denies adequate remedy and violates state constitutional provisions | CMR: defendants defended statute; Commission declined to decide constitutional issues | Held: Court avoided constitutional questions because statutory interpretation resolved the case in Brown's favor; no constitutional ruling reached. |
Key Cases Cited
- Bober v. Okla. State Univ., 378 P.3d 562 (2016 OK 78) (interpreting §2(13)(c) exclusion and distinguishing premises from "adjacent" common areas)
- Lee v. Bueno, 381 P.3d 736 (2016 OK 97) (statutory construction and de novo review of legal issues)
- McCrady v. Okla. Dep't of Public Safety, 176 P.3d 1194 (2007 OK 39) (standard for reviewing administrative factual findings)
- Wylie v. Chesser, 173 P.3d 64 (2007 OK 81) (rules of statutory interpretation and legislative intent)
- American Airlines, Inc. v. State ex rel. Okla. Tax Comm'n, 341 P.3d 56 (2014 OK 95) (application of strict construction to ambiguous statutory language)